Genpact is a global professional services firm that offers a wide range of services, driving digital innovation and running digitally enabled intelligent operations for our clients in areas including finance and accounting, supply chain management, and more. For Associate General Counsel Jillian Rennie Stillman, the key to building a great program and keeping it great is all about a focus on fundamental values and refusing to let great be the enemy of good. Interview by Bill Coffin.
What are some of the specific ethics and compliance challenges or opportunities present within your industry and how your company’s own ethics and compliance program has addressed them?
We have a global employee base of about 100,000 people across 30 countries, so we are regulated by many different systems of laws—some of which are overlapping and contradictory. That’s a reality we manage daily, and that challenge really defines a lot of my team’s work.
We address those challenges by hiring talented subject matter experts and investing in continuing education. For example, in the last year we had five additional members of the legal team get their IAPP privacy certification to improve their skills and to demonstrate to clients that we are making investments in areas of common importance.
We’re a professional services firm and we have deep expertise in finance and accounting and other highly regulated areas. What that means is that our clients place an immense amount of trust in us, because they are sharing their most sensitive and confidential data with us. To earn and maintain that trust we must have a code of conduct and a culture of ethical conduct that resonates with our employees and influences their daily conduct.
Last year, we did a significant rewrite of our code of conduct to bring fresh energy and messaging into it. We reorganized it around the concept of commitments at an individual, company, and global level to demonstrate what it means to be committed to the ethical values that we ascribe to as a company. We also translated the Code into nine languages to make it more accessible than ever.
Given the breadth of Genpact’s employee base and global nature, did you encounter any particular challenges in terms of communicating a unified set of expectations in such a way that nothing was lost in translation—literally or figuratively—when it got to the local level?
It was more universal than I expected it to be.
We are publicly listed on the New York Stock Exchange, so there are standards that apply to our code of ethical conduct. That was the guiding framework. In the countries where we operate, there are mostly similar expectations around things like conflicts of interest and bribery and corruption. Our code of conduct may be more stringent than the local requirements, and if that is the case, then the Genpact rules apply. That is the way the company has been run for a long time—employees know that the Code governs their conduct. We deal with any nuances in local and regional policies as necessary; the code of conduct is still the foundational framework.
What other recent program achievements are you especially proud of or reflect a strategic focus for Genpact?
Historically, a lot of our training was very tightly tailored to Genpact policies. Over time, that created an obstacle to updating either the training or the policies, because of this idea of “which do you fix first, the chicken or the egg?”
Last year, we took the leap and did both. We completely overhauled our mandatory code of conduct and cyber security training, moving from training that marched in lockstep with specific Genpact policies, to something that’s more modular, interactive, and modern. That allowed us to revisit a lot of other aspects of the training. For example, last year, we created a single week-long iComply training event, during which we challenge everyone in the company—more than 100,000 people– to complete their training within the same week. That way, we can focus a lot of energy and communications around it and get our operations leaders to set aside some time for their team to do the training in a way that was not possible when every employee was doing the training on their own timetable.
Do you find that having everyone do their training in the same compressed time frame mutually reinforces the overall training experience?
That’s the goal. The training was brand new last year, so there was a lot of conversation around how different it was and how the content was presented differently from prior training programs. This year will be the second time that we’ve done it, and we hope to see even more conversations around the content.
The other thing that we have been working on is making ethics and compliance resources more available to our employees. We are so big and so geographically dispersed, and the way human resources works is quite regional. It was confusing for employees trying to find a basic set of policies that apply to their conduct. So, we created Policy Central, an Intranet page where the global policies that apply to all employees are located. We are also doing a lot in terms of putting our communications and our training material where our employees are already spending time. We have a continuous learning platform called Genome that we use for all kinds of training. This year, we are going to move a lot of our training content there.
To what degree have the successes of your program opened doors for your team to pursue new initiatives?
Going really big with the Code and the training brought a lot of visibility to our team and the work that we do. That gave us a level of credibility to keep reaching for big things and making ourselves more visible within the company. We’ve worked very hard at making these projects thoughtful, useful, and engaging, and the wins that we’ve achieved have given us the boost to pull for that next thing. We just try to be ambitious about the mission of our team and get it out there in the best way we can.
Apart from the obvious connection to building and maintaining trustworthiness with your clients, how else would you say your ethics compliance program reflects Genpact’s mission, vision and values?
Genpact has four core values, and integrity is one of them. I love the way that the company articulates integrity as a value: we talk about “unyielding integrity” and that everything we do is built on a bedrock of integrity. That has been part of the company culture for years and our way of talking about ethical decision making as being a fundamental and unmovable part of who we are really does affect the culture.
The other thing is that Genpact is all about innovation and helping our clients do whatever they do better. We try to infuse that same energy into the ethics and compliance program. Instead of focusing on specific rules in our code of conduct, for example, we focus a lot on how to make ethical decisions and be an active part of an ethical culture. A prominent feature in the updated Code is a decision tree to help guide an employee in how to make an ethical decision how to get support if they need it.
Ethical companies are more successful companies. Can you point to an area where your ethics and compliance program, culture, and values have helped to contribute to Genpact’s broader success?
We win business based on our clients’ trust. They need to believe that we will be a responsible steward for their financial data, personally identifiable information, and all of their other sensitive data.
Being known as the company where integrity is non-negotiable, where there is an unyielding bedrock of trust, helps us win business. That’s the reputation that we have established in the marketplace and I really think it does differentiate us.
Also, having an effective compliance team helps limit our risk of certain types of litigation or regulatory exposure. By having a really effective program, we limit the downsides. Our program doesn’t always help the top line profit number. But mitigating risks and limiting the downside is a way that we contribute to the overall financial health of the company.
You mentioned how integrity is a fundamental value at Genpact. Can you speak to how a company’s behavior positions it to succeed not just in the marketplace, but in the unique leadership role society expects it to fulfill?
We announced our company purpose within the last year, and we talked a lot internally and externally about who we are and why we do what we do. We define our purpose as: the relentless pursuit of a world that works better for people.
I think that that really highlights how we help our clients do what they do better. But it’s beyond our clients.
For the past several years, our Corporate Social Responsibility program has focused on hunger, and on ways that we, as a company, can address food insecurity beyond contributing financially or going to a warehouse and packing boxes of food. I mean, we do all those things. But for me, one of the most interesting things that we are doing is our relationship with this company called Not Impossible. They have an app called Bento, which is a text-based app that connects people who are food insecure, and in need of a healthy meal, to restaurants in their local area where they can get food free of charge. It is a perfect partnership for Genpact because we can use all of the digital analytical experience that we have honed over the years with our clients to improve the analytics and operation of this kind of program. Bento’s founder spoke at a Genpact conference recently about how hunger is really an information problem–there is all this excess food and it’s just not getting matched up to the people who need it. That kind of process improvement and analysis of large quantities of data is exactly what we do. That partnership is one that reflects what the company believes and shows what we can do for the world in a way that’s meaningful for us.
You seem like you really like your job. What do you like most about it?
I love my job. It is intellectually interesting every day. The number of legal issues that arise in a company with our footprint is endlessly varied, and we serve clients in so many different industries that sometimes compliance issues that affect them affect us. So, there is this environment of constant learning.
That was something I didn’t want to lose when I left private practice as a litigator, when every case was a fresh universe of things to learn. And that is more true than ever in a company like Genpact
The other thing is the company is really open to people just having ideas and trying stuff. There is a faith in people, that a person will come up with something interesting and do the work to make it succeed, and if you fail, you fail. That has really allowed my team to look at things in a fresh way and ask what we need to break, what we need to fix, and how else we might approach our mission.
This is not Genpact’s first time as a World’s Most Ethical Companies® honoree. Any thoughts on what it takes not just to create a great ethics and compliance program, but to sustain that high level of excellence?
Genpact has had a mature ethics and compliance function for a long time. Because our regulatory environment is continuously changing, though, we also need to change. Personally, one of my biggest challenges has been letting perfect be the enemy of good. That mindset can get in the way of getting started. Instead of defining an end goal that is perfect, we have adopted a mindset of continuous improvement. Just starting with any baby steps creates momentum, and identifying and pursuing “quick wins” helps gain support outside of the team, which allows you to build on your successes.
