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Expectations are probably working and it's learning first walked in the conference room this morning I opened the door and the first person speaking at the podium is a former colleague of mine at the Department of Justice and a former colleague of mine and somebody who I've stayed in touch with and we mutually network. So to me that is a great sign of what I'm expecting going forward and it was great to say there definitely are some of the the leaders the boardroom leaders and some of the business leaders I'm particularly interested in hearing and and paying attention to those panels in terms of subject matters and topics you know there's so. Much to cover and you can't I can't you can't be at every every panel bribery is something that my company pays a lot of attention to and it kind of is my area of expertise so actually I'm. More interested in learning about things like cyber and spending a little more time on areas that are obviously emergent very important cyber communications training is actually something that my team is using putting a lot of attention towards so things that are not necessarily directly on are obvious we were on wheelhouse. Or the place where I'll probably gravitate more towards I'm very proud of our program I came about four years ago and I inherited a. Very good program I think. We've made some very good changes having said that any good compliance program you've got to evolve you've got to keep changing so so one thing we've done I'm very proud of over the. Last year or so is training and communications we noticed a while back we have. A very good standards. Of Business Conduct code of conduct we've got we had very good training but our sense was it was good it. Could have been better maybe a little long maybe a little bit of a kitchen sink approach and we really gave a very hard fresh look at our at our annual code of. Conduct or SPC standards of Business Conduct training and other training and communications as well and what we did with our annual SPC training in particular is just just whiteboard of it we kind of looked at where our big risk areas where the things that where we really want to make sure people are particularly focused on and what. We did was we made it shorter. We made it more targeted we actually created modules so now if you're an. Employee at the company everyone doesn't get the same training you if you're in if you. Have one employee profile you may have a certain type of training another employee profile they may have a different type of training it's more modular it's more conformed to the kind of. Work the particular employee does so what we've got is shorter more targeted better and more accessible training just a quick anecdote it's just a month or so ago my office got a call from an employee who self-reported she said I have a concern I think I've been doing something wrong here it was the. Books and records issue and it actually had been doing something wrong in good faith but it could have been a real problem for the company had it not been detected that she and she and her team had been doing it for a while she said she she she read the. SBR SPC training and she has a finance background so it was particularly focused on. Her she thought better of it and she reported to her manager and then to us that is about as good as you get when it comes to training info training. So I'm particularly it happier than proud of the training that we've been doing and. She's trying to continue to do you won't want just people to read it because everyone. Has to read it they're gonna read it because they have to they. Get they get you want them to read it and absorb it and act on it and and. That to me was a great example that part of it is obviously leadership it is a part of our culture one of our tag lines and almost all of our presentations. Internal my presentations is winning the right way doing the right thing in particular winning the right way it is leadership we do have a very strong tone at the top I report to the general counsel who as who he and I. Have strong lines of communication with the audit committee in the board the CEO CFO so honestly it comes from that leadership down to the. Next line of leadership and a lot of face-to-face and direct interaction with the other senior leaders of the company we really are doing it with great results we're a big multinational company. We're in all over all over the world we have different areas of risk anti-corruption being. One of them but only one of them we've hired a lot of people from the Department of Justice and the SEC I think right we probably over the last five years of hired probably ten different people with DOJ. Or SEC backgrounds many of them are still here we've got a couple of people with that background in Asia doing investigations for us we have a couple of people in in Europe and people in the United States doing that the hiring of people with that background a particular investigations background and I bribery. A background SEC background gives us first of all it frankly it saves us money we're able to. Really leverage our own resources our. Own talent and use outside counsel in a more targeted focused way like we leverage them and use them but but still we can do a lot of the work in-house at least initially but also it really brings people in who really know. The company really know the business and really know law so one thing. I know a lot of companies are doing but we really have been doing this for a while and we're if anything doubling down on that idea is just bringing in hiring and to. Work at our company real experts and putting them in the regions not just. At a desk in Washington or Palo Alto but putting them in Asia putting them in New York to actually get. On the ground and interact with the business leaders and actually conduct a lot of the investigations themselves it is again part of its. Targeted training part of it is getting the right leaders to to invest in it so people want to hear from me that's great they really want to hear from the CEO they really want to hear candidly not just from the CEO but that that the kind of the SVP s not. Below the the the CEO who are in the ground the people frankly. Who signed their paychecks who would give them their bonuses who set the tone in the culture so what we really do and I think we do it. Effectively and continue to work on this at our company is really engage on a regular basis. Not on it once a quarter but on a fairly regular basis with those VPS those senior leaders and have them understand what we're seeing share with them trends we're seeing that share with them concerns we have or particularly bad fact patterns that we come across and the direct engagement not on. A semi-regular but on a real regular basis with the engine of people the leaders who really run the company and that engagement and that trust frankly has been very effective the other thing is I do think they trust me and my team they realized that my sometimes I have to say no but I'm trying to say. Yes as much as possible and if I say no it may be with a solution where we can do something more ethically and more compliantly so I get that we're a company here to make money in a profit. For shareholders and they get that I get that but they also know that I have a line I won't cross that lines I won't cross and then if I come to them with an O or concern they're gonna listen they're gonna answer the phone and we're going to put an honest conversation I don't know if it's unique. That we're the only. Company that does it in the world but I do when I benchmark it's something that I think other companies do maybe not do as much as robustly as we do or intriguing to want to do that so what it is is we have again more direct engagement with business leaders so one specific example. Is a program we call our liaison program what it is is when my team investigates some of the most serious ethics investigations that the company of the kind that you reports at the Audit Committee are instant young the kind that are really of interest to me and the real. Leadership of the company before we do an investigation before we actually decide the outcome meaning if somebody has to get fired or reprimanded or if we have to take serious remedial actions we actually present that case in a report and then often there's there's a call. We have with business leaders not just legal but we get people from the business involved we have people from HR involved with people from finance involved. And we have people from legal so what we do is we have essentially the liaisons are. A group of elders there are group of senior. People who have legitimacy within the company who actually decide what the outcome should be that has a lot of great effects one is it gets consensus one is it educates business leaders as to issues that they should know about whether it's in their region or on their team or in another. Region or another team and it obviously gets buy-in so when or if there's pushback which occasionally happens the business and the finance and the HR and legal are aligned and are all bought in so that regular engagement with real business leaders in particular is good I've seen in other companies where. There is a bit of a distance and there's a bit of attention and there's a perception that that legal or ethics. Is just judge and jury and they're just. They don't get it when you get that direct engagement from the business the right business leaders it just works so much. Easily so that's something that again I think other companies do we do in a very structured formal way where we have regular meetings we have regular reports with regular process and it works great the other thing we do is we. Have what's called an ethics and compliance committee and I think other companies do this as well it's something we did many many years ago it's evolved over the years but it's really it's. Been great so what it is is we have our audit committee we have our instan you know we have our outside auditors and we have other regular cadence within within the company throughout the year those senior leaders level well we have is an ethics and compliance committee it is a quarterly meeting. That I chair that I run and it's got most members of the executive committee there it's an hour once a quarter at least sometimes more and sometimes we meet more than once a quarter where we sit and my team presents for an hour on trends issues concerns particular investigations initiatives it's it's my. Opportunity to have an additional inflection point an additional force force conversation good force conversation with the real leaders I take that very seriously that our it's very valuable hour of their time my leaders do but we really use it to good effect to get to get ideas get and get engagement from them so. We do that what we're doing now is my team does not directly handlers handle cyber but the cyber team has seen how well this works so they're setting up their own. Separate model a force a compliance committee based on the model that we've set up so the success that we've had really getting that engagement on that are areas of risk the ethics compliance. Areas of risk that my team handles is now going to be leveraged and now month the cyber team is going to have their own quarterly. Cadence with that same group of senior leaders of the company so it's a model that works well if you make sure you use that time properly the the the senior leaders HR finance the business leaders they get it and they want to hear what you have to say it's an area my team has. Is responsible for privacy there's an obvious connection between cyber and. Privacy but but very separate so issues like the GDP are. And basic core privacy issues or what my team handles but cyber is it's it's obviously it's in for a company like mine which is a tech company you've really any company any multi national company it could present an existential threat if it's if if you really have a big crisis so you got to get a right we have. A great separate cyber team that I partner with on a very regular basis for obvious reasons there's an obvious connection whether it comes to investigations or privacy but it's a it's a huge area risks that. My company spending more and more time on getting more and more senior audit committee and board. Level of visibility to. What they're doing.

 


Hewlett Packard Company News

Thu, 09 May 2019 12:36:58 GMT
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