Luciana Rodrigues (pictured right)—born and raised in Brazil—started her corporate in-house lawyer career in 1996 when she joined MTV Brazil’s legal department. Since then, Rodrigues has worked for multinational companies of different industry sectors: Volkswagen (2000-2003), BOSCH (2003-2009), General Electric (2009-2013), and Syngenta, where she currently holds the position of Regional Compliance Officer for LATAM. In her role at Syngenta, she collaborates with the global compliance team while supporting senior leadership to continuously strengthen and broaden Syngenta’s compliance program.
Here, she spoke to Ethisphere’s Aarti Maharaj about how the Board should support compliance initiatives.
Q: During your 20 years of corporate experience, what do you think are some of the greatest lessons you’ve learned in compliance or corporate governance?
I think that the most important lesson that I have learned is that a compliance program cannot be separate from the business, in fact, we want compliance to be successful and embedded across the company. For instance, never take for granted that employees know what to do, leadership and middle managers need to walk the talk too.
Making an ethical decision is not an option, we have to talk about compliance with our employees—its about the company standard, how the company expects all employees to do business.
Another important point is that we need to be effective communicators. I’ve noticed that even if a manager talks about compliance, not all employees will understand it immediately. It’s a process. People need to understand the rationale behind making an ethical decision because it drives a better culture.
When it comes to the governance of an organization, we need to be fair and smart at the same time. If we are too controlling with an added layer of requirement—where everything must be approved—it won’t keep employees engaged. At the end of the day, you want to keep policies and procedures simple, you don’t want to paralyze the organization and its culture—you want to build and sustain it through simplicity.
Q: Corruption: It’s like riding a tiger without being eaten—can you explain this more?
People have realized that corrupted governments, politicians and environment won’t make the nation successful. It is clear: all of the country’s growth was hidden by corruption. Brazil’s growth was not sustainable and now the country has entered into a recession. Right now, we don’t have access to proper hospitals, education, etc. – so how can we build programs and develop under this situation? Communities and organizations have learned that this is not a sustainable approach and turning a blind eye on bad behavior does not help either. So having the appropriate governance model in place would ensure that employees know that they could speak up. It is impossible to issue policies enough to cover all kind of situations. Think about it this way, what if you issue a policy, train your employees to operate strictly by your very detailed policy and then, on a day-to-day basis, your employee faces a gray situation, which is not highlighted in the policy? Let us suppose that it is his or her key decision of the year that can result in achieving or not achieving the financial targets for the year.
Let’s also assume that there is not a speak-up culture in the organization so the employee is not comfortable to talk about compliance dilemmas. Just add the fact that employees may not really believe that his or her manager cares about ethical decisions as the employee himself has experienced his or her manager in many instances walking through the gray zone not covered by the policy and never having a transparent conversation about it. You want to train your employees to move beyond being policy-oriented and we need to work on compliance culture and that can be done if we have smart governance mechanisms in place to ensure that your employees don’t have any doubt about doing the right thing and that they will speak up whenever something does not seem really black and white.
Managers (or better yet, great leaders) also walk the talk meaning that they engage in open conversations in the day-to-day with his or her team to ensure everyone is on the same page and address any perception that he or she has incurred in any wrongdoing.
Q: What factors are shaping how the Board views and engages with Compliance or the Compliance officer?
You cannot afford to have a breach in compliance and this is where Board oversight is essential. Compliance ensures that employees know what to do and they know the way we do business and how we follow standards around the the globe. There are some countries in LATAM that don’t have private anticorruption laws, such as Argentina, México etc., but it remains important that the Board ensures the highest standards of compliance and integrity out there—despite the lack of regulations—it’s up to us to continue to do business the right way.
Q: Employee engagement: What are some best practices that you use to promote employee engagement across Syngenta and why is it an important area of focus for the Compliance Officer?
Going back to my point about communications, it’s much better to put in place a “help line” instead of a “hotline”. Having clear communications keeps employees informed and involved. In turn, this creates a place where employees feel comfortable and contribute to the overall success of an organization. For compliance, in order to protect a company’s reputation and ensure its long-term sustainability, compliance should continue to empower employees to make the right decisions.
Q: How does Compliance communicate to the Board?
We work in tandem with each other and I communicate with them every day. When we talk about formal communications, we have a global compliance and risk management committee in place. Our regions and territories have their compliance and risk management committees as well and in this meeting we discuss compliance and risk topics. It is in these meetings that we discuss the metrics of the help line and report on the compliance activities within the specific regions. The Board wants us to continue to share what we’ve learned through the use of the data presented.
At the same time—how do we provide transparency and information to the Board without breaching employee trust? So we share our experiences and avoid getting too specific to maintain trust.
Ethisphere’s 2016 Latin America Ethics Summit is happening on June 8-9 in Sao Paulo, Brazil. Meet and network with industry leaders along with members of the C-suite, who will gather to discuss and promote corporate integrity and performance. For more information about this exclusive event and to register, click here.