For nearly 23 years, Mike McLaughlin worked at Dell Technologies (an 11- time World’s Most Ethical Companies® honoree), first as an employment lawyer and ultimately as its Chief Ethics and Compliance Officer—a post he held for a decade until he retired in August 2023. Mike spared some time to speak with Ethisphere about the lessons he learned during his career and offers some advice for those whose professional journeys have plenty of road left in them, including with something he tells everyone: “Be that guy.”
What brought you to Dell originally, and how did you become Chief Ethics and Compliance Officer?
I had worked at Morgan Lewis, a well-known law firm in Philadelphia and then went in-house at a company that is now part of Dow chemical company, where I concentrated on employment and litigation. In 2000, Dell was looking for an employment lawyer and I got the call, but I really wasn’t looking to relocate. I had family in Philadelphia, and my roots were there. But Dell was so exciting to me, being part of the so-called New Economy, so I interviewed with them. And let me tell you, I felt like I was visiting another planet. The people I met there, the culture that existed at the company, the excitement, the optimism, the vision of Michael Dell and his leadership team…it just excited me more than any other job I had ever thought about. So when I got the offer, I jumped at the opportunity. And Dell has remained that same exciting place throughout my 23 years there.
Being an employment lawyer at Dell was an absolute joy because Dell is a company that really tries to do the right thing. Look, we’re not perfect, and we’ll never say that we don’t make mistakes. But if a mistake is made, we fix it. I am someone who has actually reinstated employees, which is very unusual for an employment lawyer. But there have been times when I have gone to the top leadership and said, “Look, I think we made a mistake here, and I think this person deserves their job back.” And we gave them their job back.
Another reason I feel so blessed to have worked for Dell is that even though it is a very big company with many different products and revenue streams, it is very, very streamlined in the way that it is run. We have Michael Dell, who is the founder, chairman and the majority owner of the company. He has an executive leadership team comprised of relatively few people, one of whom is Rich Rothberg, General Counsel, who was my boss. Another is Jeff Clarke, Vice Chair, who acts as Michael’s proxy when Michael’s not in the room. In my 23 years at Dell, you could get things done with just one meeting, because we are led by people who are really good at making decisions. They’re very active and very available. I had Mike Dell’s cell phone number and if I needed to, I could call him and he could make a decision, and that was that.
So when you get a company that has a good heart, that you can trust to do the right thing, and that has clear leadership and clear alignment, you can accomplish an awful lot.
Can you talk about how you were tapped for the role of Chief Ethics and Compliance Officer?
In 2010, Rich Rothberg—who at the time was just a very good friend and not yet General Counsel—approached me and said that even though I was doing very well at my employment law job, he thought I could do more. He told me that the top ethics and compliance position was being vacated, and that I should do that job, too. I thought I could do it, but I was nervous. I knew employment law, employment litigation, even ancillary litigation really well and I knew I could succeed at it. I didn’t know this other area and I was a little scared of it, so I suggested we take a year to think it over and in the meantime, I’d learn what I felt I needed to learn. Rich told me no. “You’re not going to fail.” And he went to the General Counsel and told him I should have the job. A day later, I got the call to take it on.
That moment taught me two important lessons. The first is that even though I had been doing employment law for 25 years, and felt really good and secure about it, it was important that I took that risk to do something completely different. The second is that your friends and your colleagues are often your best career advisors. Rich knew my career path better than I did. He was more confident than I was. And it all ended up bring the best thing that happened to me. But I was reluctant, and Rich wasn’t.
You describe your method of ethics and compliance leadership as “winning hearts and minds.” Can you explain that?
My background is in litigation. And I am a firm believer that trial lawyers win the heart of the jury first and then they bring their minds along with reason. The jury has to believe that your client tried to do good and tried to do right. And that was the only way I could do this job— by talking to our 140,000 or so team members and wining their hearts. I had to talk to our many thousands of team members around the world and tell them that what matters is that first, they have to do what’s right. All the rest of it will follow. You have to believe that this company will always try to be a force for good in the world and that if we mess up, we will admit it and then try to fix it right away. That was the approach I took, and I immediately put it into play.
I had a huge advantage being the lead employment lawyer for the company, because every leader in the company knew me. I either negotiated their entrance agreement, or if they worked for a competitor before coming to Dell, I negotiated that. Some of that involved litigation. So they knew me well. And I went to them and said that we all care about ethics. We care about doing the right thing, and about the company’s name. I said I needed their help in making sure that their team members believed in that, too, so I would need time on their calendars in their executive meetings, and in their all-hands. I knew all of these people very well. And they gave me that time to go and speak to team members around the world.
Now, when you have that kind of opportunity, you can’t waste your time by being boring. You don’t want to talk about rules—these five embargoed countries, and these privacy laws in Europe, and so on. Tell people stories. Tell them the incredible things that are in the news, stuff that they wouldn’t even believe. You don’t have to look hard to find these incredible stories of money being transferred illegally, brown paper bags being laid at doorsteps, that kind of thing. There’s a famous saying that stories put babies to bed and send soldiers to war, and that’s true. People will listen to a good story and remember it, and that is a great way to win their hearts and minds. They have to know the rules too, but you can embed them in the stories you tell. And that’s how I started.
But then you took that storytelling approach to the next level in the digital era. Can you talk about that?
I look at digital as two buckets. The first bucket is using digital to enhance the ability to tell stories to exactly the right people in exactly the right way at exactly the right time, and in the exact dose to be interesting. We made great strides there and now we have an app like YouTube or TikTok where we can reach Dell employees on their phones, and they can watch videos on exactly the topic they need. We can push it to exactly the people who need to seem them in three to five-minute clips. And we can localize the content, too. There was one time we wanted to send a compliance message to our sales team in South Korea about following the rules and doing the right thing. We engaged our local employees on this, who were super-creative and incorporated a Korean folktale about the Nine-Tailed Fox with the messaging. We pushed that out to everyone who worked sales in South Korea, and when we monitored whether people looked at the message, we could see that it really resonated with them.
Something else we did was inject humor into our content. We hired a company to come talk with us, and help us create some funny videos around the stories we wanted to tell. We had some skeptics around that who thought we weren’t taking our clients seriously, or that the government wasn’t going to like it, or that we were being frivolous. Well, we showed the content to some friends who were either from the government or who were going into the government, and we asked them what they thought of it. We said we thought it was compelling because people would remember it. And they said, yes, that is exactly what you want: for it to be memorable. Whatever the story is, it shouldn’t be boring, or forgettable, or just check the box. And if you can make it funny in a way that isn’t disrespectful to the subject matter, and make it memorable and story-based, then that’s what the government wants.
The second bucket is predictive analytics, which is nirvana for compliance people. We developed a system called CARDS (Compliance and Risk Detection System) that looks at deals and can tell if they are high-risk or not. That name sticks in your head and lends itself to more storytelling. We would say, “Put your CARDS on the table,” or “Show your CARDS.” Things like that actually got worked into our videos because it is all about transparency. We all know that any kind of corruption carries some of the biggest fines possible. And bribery only happens one way: with money. You need money to bribe, and there are very consistent methods to get it. You look at bribery cases, either someone creates a false company and feeds it money, or they over-bill a company and feed them the money, or they use cheap discounts to orphan funds to use as bribes. CARDS looks for those orphaned funds and deals with deep discounts, or deals with third parties that maybe don’t deserve to be involved. It’s only just beginning, but just imagine what it will do when the AI and machine learning make it what it can really be. It will be able to look for risks and say, “this discount makes no sense in this country with this partner.” And then we can come in and stop it.
We also have a similar fraud detection system that uses data analytics to detect fraud risk and stop it beforehand. The key is not to get too many false positives, and we are probably only halfway to where we want to be on this. But with machine learning I have a feeling that is going to get exponentially better in the next two years as any false positives get fed back into the system to help it learn. I am really excited about what predictive analytics can do.
What would you say was the secret of your success at Dell?
It’s tempting to say there is a secret to success, but the truth is there are many pathways to success. For me, finding the right organizational fit was key. The excitement around Dell, and its culture, has always been unbelievable. When I joined Dell, Michael Dell had this vision of democratizing technology and making better machines than other people could make, and making them so more people could afford them, so that people all over the world—including children in school— could have access to them and level the playing field in many ways. That’s amazing. And that was a mission and a purpose I was deeply excited about—technology as a way to enhance human growth, development, and even joy. And I got to be a part of that.
It wouldn’t have worked if Dell was a slow and plodding company, or if it was difficult to navigate. For example, we did benchmarking a lot. And I’ll never forget when I was talking about investigation metrics with someone from another company, and I mentioned how we tried to finish all of our ethics investigations within an average of 30 days. The other person looked at me and said they didn’t even start their ethics investigations within 30 days. I couldn’t have worked for that company. I found a company that moved at my speed, one that had the same crisp, fast, data-based decision-making processes that I really enjoyed. But most importantly, the thing that was non-negotiable for me was working for a company that was doing the right thing and had its heart in the right place.
I had the privilege to work directly with Michael Dell on many things. And in my entire 23 years, I never once went to him on a matter, and he said, “Let’s just do the expedient thing. Let’s do the wrong thing. Let’s brush this under the rug.” Never once. He always said, “What’s the right thing to do? Let’s do that. But let’s do it in the smartest way, and in a way that protects the company. But let’s do the right thing first, always.” And that was such a joy. I had to have that commitment to doing the right thing, first and foremost, and with Michael Dell and his company, I found that in absolute terms.
Any final words of advice?
If you Google Dell, you’ll find all kinds of news stories about the awards we have won, and about our culture. But if you look around 2013, you’ll find an article in the Milan Press where there was an attempted bribe. One of our employees came forward about it, and we stopped the bribe. We went to the Italian government and told them, and they fired their bad guy, we fired our bad guy, and that summer, we were in the local news for helping to clean up the government. It was just one person in one position, but we were in the news for helping to clean up the government.
I have told this story in every speech I gave at Dell, and I always ended it by telling people: Be that guy. Be that guy in all the things you do for this company. You will never, ever, do something that helps the company more, no matter what you invest, no matter what you create, no matter what you do, no matter what customers you help, than what that guy did. Because the price a company can pay for corruption can go into the billions. That’s an awful lot of technology to sell. So always, be that guy.
ABOUT THE EXPERT
Mike McLaughlin retired from Dell Technologies in August 2023 after serving the company for nearly 23 years, most recently as Senior Vice President, Chief Ethics and Compliance Officer.