Vice President, Counsel and Corporate Ethics Officer, Alliance Data

Written by Ethisphere

CEOs may set the ethical tone from the top, but they need a supporting capable cast to tend to the day-to-day implementation of the company’s compliance and ethics programs. What are these leaders on the “front lines” talking about and doing these days?

E: Tell us what your group is focused on these days?

KW: It’s not a big group, it’s a group of me and another person who is our Ethics Director, and we’re focused on doing some planning and preparation for 2014. This includes training initiatives for next year and planning an ethics week.

Primarily on doing a Speaking Up campaign, or focusing on anti-retaliation and whistleblowing kinds of initiatives. We are really ramping these campaigns up this year. And of course, we are still working on the regular changes, changes to our codes of ethics, etc.

E: Are there any particular initiatives that you have found worked well and you would like to share with others?

KW: We do an ethics week, which we started back in 2011, and it did a tremendous job of raising awareness for our ethics program. Being such a small department, and back then I was the only person in charge of the ethics program; it took us a while to get to the point where we had the resources, both monetary and support, to actually get this week launched.

It’s a great way to focus just on ethics for an entire week, and hopefully engrain that we do in fact do this on a routine basis – recognizing that this is not just a one shot deal, but we do continue to do activities throughout the year. It’s very important for people to get the support of their senior management, and we had several of our senior team film vignettes that were incredibly successful with our employees.

We are very fortunate to have a group of senior leaders who are so committed to our program.  These initiatives really do require all hands on deck. 

E: What part of your background has most prepared you for this position?

KW: My personal opinion is that my legal background, with a focus in employment law really helped to prepare me – mainly because we have 11,000 employees across the world. Being the primary counsel for the last 15 years and focusing almost exclusively on employment has given me exposure to a lot of compliance initiatives, HR policy compliance, and I’ve dealt with various employment issues that have arisen internally.

Coming into this position, I already knew that employees are generally afraid to come forward – afraid to bring up their concerns, fearing their actions could negatively impact themselves or their jobs. We made our first real focus in our ethics program on securing our employee hotline. We made it clear to our employees that it is an anonymous source line for their work-related complaints, if you will, for lack of a better word. And I hate to use that term, because that isn’t what the line is for – it’s for legitimate good faith concerns from our employees about whatever is happening in their work environment.

E: Is there one specific piece of advice that you would like to share that you wished you had known when you first got the job?

KW: I would say the biggest piece of advice I can offer for anyone starting out in an ethics program is to not be frustrated by the resource constraints or the commitment constraints that you may encounter in the beginning. It takes times to convince and/or build rapport with enough of the senior leaders to get a program off the ground.

Early on, generally speaking, many people thought that an ethics and compliance program was a check the box sort of program – today, it’s complete different. You still have to be patient and you have to build the consensus along the way. It takes focus and persistence.

That being said, I believe that patience and fortitude are the two most important traits a new corporate ethics officer possesses.

E: To whom do you report? What role have they played in the compliance ethics program?

KW: I report to our corporate general counsel, she is someone who has been in that role for the last three years.  She is just one level from the board, so we have a lot more focus on the program in the last couple years; she has provided me more resources than I had before. Additionally, our CEO changed, and our current CEO has a different perspective about our business in general, and very willing to give the resources we need to the program.

E: What keeps you up at night?

KW: You know, I was thinking about that earlier today and what keeps me up at night are those black swan events, those events that no one can possibly predict and no one sees coming. What else is around the corner? That is what freaks me out! Whether with the economy, or with business, another Leman Brother situation, for example – Though, I think in general companies do more good than harm, and I think the chances of those being frequent events being very slim, but nonetheless it is certainly a possibility. Those possibilities are what keep me up at night. 

E: What’s the worst job that you have ever held? (Usually it is some job during college or the summer – or possibly even straight out of college) And why?

KW: When I was in high school I worked in fast food, and though, admittedly I liked to eat it, I didn’t like to work in it. I was young of course, and it was good in some respects, though I didn’t stay with it for long, contrary to my typical nature. And when they told me I had to work New Years Eve, I quit!

E: Thanks for speaking with us, Kellie. It’s been a pleasure.

Expert Biography

In her role as the top ethics officer for Alliance Data and its three businesses, Kellie developed and oversees all aspects of the Company’s global corporate ethics policy, which has received one of the highest ratings by a leading ethics and compliance consulting firm against nearly 1500 ethics policies.