Activision Blizzard King (ABK) is one of the world’s foremost producers of video games such as Call of Duty, Guitar Hero, Diablo, and Candy Crush Saga. The company’s recent $68.7 billion acquisition by Microsoft was the largest ever for both Microsoft and the video game industry itself, making Microsoft the world’s third-largest video game publisher. As a highly scrutinized, highly public company, ABK’s immense ethics and compliance expectations require a special approach that balances best practices with its own unique creative and cultural elements. That’s why for Jen Brewer, ABK’s Chief Ethics and Compliance Officer, driving an enterprise-wide mission, set of values, policies, and procedures at a company that’s all about playing games isn’t just serious business. It’s serious fun.
In your job title, ethics comes first. Why is that?
Adding “ethics” and putting it first was very intentional. Compliance is not a word that means much to most employees, and the entire focus and mission behind our program is connecting with individual employees. Ethics, on the other hand, means something to almost everyone, and it also goes above compliance. If compliance refers to remaining compliant with all laws, ethics requires more than that—it pushes us beyond meeting the letter of the law to asking what the right thing is in every situation.
What are some of the unique challenges and opportunities within ABK that you face, and how do you solve for them?
In addition to having a global footprint globally, we have a unique structure of business units, studios and cultures. Activision Blizzard grew by acquisition, significant ones like Blizzard in 2008 and King in 2016, but there were also lots of other studios along the way. That means you have employees in different business units and studios who really identify with their local studio or their business unit more than the larger organization. There is great benefit in those unique cultures that oftentimes reflect the games they make, but it can also be challenging when delivering consistent messaging or policy.
We start from the premise that every employee, whatever their level, location, or job, is our priority. To meet every employee and make sure they are included, we need to make sure our program speaks to the unique cultures within our regions, our business units, and studios and amongst varying types of employees—creative and technical folks within our studios, corporate employees, and more. Seeing things through that lens is our priority, and everything flows from there.
For example, when we closed the King acquisition, we didn’t just roll out our policies and code to King; we flew to London and spent time getting to know them, collaborating with them to create a new Code and new policies that would reflect our global employee base. We leveraged some of what they did best, too, such as adding color and graphics to our policies and incorporating their voice when drafting them. Did it take more time because we did it that way? Sure, it did. But if we had rolled out policies without bringing them along, they wouldn’t have had an impact.
We also spend a huge amount of time and effort on our ethics and compliance road shows, intending to visit in person every location around the globe to provide training and support, but also to hear from them and to understand what they do so we can bring back an understanding of their needs, successes, and challenges.
Way2Play is the internal branding for our ethics and compliance program, and our Way2Play Heroes program is one of the things I am most proud of. It is our local ethics and compliance champions program, which launched in 2018 with a 3-day summit in Barcelona. We have over 140 heroes today, reflecting every location and function around the globe. They provide feedback to us, they champion speaking up, they serve as a resource within their locations. This program that truly empowers the voices from every location and team around the globe was a huge step forward in our work to bring together all pieces of the ABK world.
When it comes to our policies and our communications and training, this too is top of mind—having policies that speak in approachable, understandable language comes before legally and technically exact, we prioritize translations and communications that speak to employees and explain the why. We also talk to our heroes before we roll out any policy at all.
For you and your team, what does success look like at Activision Blizzard?
Success from my lens looks like continuing to relentlessly pursue progress in all areas. The work we do is always about the journey and not the destination—we are always pushing forward better and more approachable policies; more transparency, accountability, understanding, equity, integrity; more impactful training, programs and infrastructure that meet employees where they are and with what they need. Success means earning and maintaining trust and credibility, that we remain a trusted resource for all employees, for leaders, for business units, for every function. It also means that our data reflects our efforts, and that we leverage it to determine where our next efforts must go. We want to see employees continue to speak up and share concerns they have; we want to see consistency across the business for accountability with concerns and how they are handled; and we want to be able to act quickly and proactively whenever data appears to show a trend.
We have done a lot of things that I am very proud of in all areas of our program—policies, training, investigations, Heroes, road shows, data, and more. But we must continue to drive forward on all things, because success is achieved one day at a time and one conversation at a time, every time an employee feels comfortable enough to speak up.
What makes ABK’s approach to compliance and ethics unusual or unique?
Our driving focus and principal goal— and I mean this as a goal for our whole function as well as a goal for each individual member of my global team— is people first. That means in everything we do, whether it is training, or policy, or investigation, or communications, or data, we prioritize people first. So rather than beginning with the legal or regulatory requirement or the issue at hand, we begin with the people always. That changes the lens through which you see everything. That doesn’t mean we don’t prioritize the legal or regulatory issues, of course, but we do put the human lens on everything first. There are big examples of this focus, like our Way2Play Heroes program that trains and empowers heroes from around the globe, or our Road Shows, or our extensive live training commitments. But there are also smaller examples of this too.
For example, when we were getting ready to launch a global training this year, we received feedback from certain international locations that they didn’t feel the training content was really reflecting their local voices, language, culture. So we hit pause, retooled the training entirely, canceled sessions for several weeks and launched the training after we had taken all that input and had something that would work better for those regions.
Another example is that we look at cycle times for concerns. We do that because the employee experience has to be our priority through an investigative process. When we see cycle times that we want to improve, we will go to process and streamline whatever we need to in order to make that change.
Gamers are a deeply opinionated bunch. How do you turn that challenge into an opportunity insofar as making a meaningful connection with your client stakeholders?
It is fair to say that we have many employees who are deeply passionate about the industry and have clear views. That has meant we received a lot of feedback. And that is the one thing that my organization needs to really be effective. So we took that and said “let’s go!” This is quite honestly the inspiration for the Heroes program. We had people with powerful voices and loads of integrity, so leveraging them and making them part of our team enabled us to do more and have a bigger impact than we ever expected.
I think almost every perceived challenge is an opportunity when looked at from the right lens, and having employees who care deeply and are vocal is exactly what gave us the feedback, insight, and framework to build out what we have today. Way2Play isn’t a corporate voice—it is made up of all of our voices around the globe. To build that meaningful connection, we apply and practice a few core principles: 1) Listen, 2) Play fair, 3) Be authentic and transparent, and 4) Encourage speaking up and model doing the right thing.
Ethics and compliance is increasingly seen as a way to do more than just manage risk. How would you say your work is helping to build value at Activision Blizzard?
To consider ethics & compliance as a risk mitigation function is to sell it short. Done right, a fully empowered ethics function can change the direction of a company, build credibility and trust, help root out friction and problems in businesses that impede value. It can bring more life, more connectivity, and a common language to a global population. People can come together in these spaces and that can directly benefit the business. This goes well beyond risk mitigation and have a direct impact to the value of the business and the culture and trust of our workforce.
When we first brought together Way2Play Heroes, we had no idea all the ways they might integrate and partner with us and with each other, and what happened vastly exceeded our expectations. Teams from various parts of the company began partnering to elevate and address challenges and issues that impacted them all, rather than siloed teams working separately to solve similar challenges. They were able to partner and fast track and solve challenges once. Sometimes conversations initiated by Way2Play can raise topics to the surface that otherwise people have a tendency not to bring a lot of awareness too.
By starting those conversations and connecting people, we solved problems and created value well beyond what we ever set out to do. Also, when you address concerns on a team quickly, transparently and with accountability, you are able to handle with care and resolve issues that often leave a team working together with more trust and more effectiveness.
Through our Heroes program and through our other Way2Play channels we receive feedback well beyond the topics that people might consider us responsible for. Being able to get that feedback to the right place directly and quickly has enabled solutions to challenges all over the world and well beyond our scope. The Heroes themselves have become a sounding board for teams and leaders throughout the business.
We develop language driven by what we must do to foster supportive cultures, rather than just dictating what people can and can’t do. No one likes being restricted and controlled; implementing supportive communication networks that facilitate new ways of thinking is key to a company’s successful evolution. As a result, we don’t just send messages out from the corporate office. Instead, we work collaboratively to begin organic conversations with one another. Action without collaboration can often be tone deaf or ripe for misinterpretation. Collaboration without action is just wheel-spinning.
What are some of the most important career lessons you learned that you can share with your fellow ethics and compliance colleagues, especially when it comes to things like working with the C-suite, employee engagement, and measuring program effectiveness?
This is a marathon and not a sprint, so think of everything as the long game, not the short one. It’s about building relationships all around, understanding the business and employees. You can’t change everything all at once, and it takes a journey to move the things that really matter. So drive hard, but be patient and choose your moments wisely.
Always take a call from employees, partners, or leaders in need—never be too busy to hear a concern from anyone. Pick the things that matter most and will have the most impact. Be prepared to change directions. Be prepared to learn from employees and the business and go a new way that makes sense for all.
Trust and staying true to your word are foundational in this role and in building trusted relationships and a support network. Trust your instincts and remember you don’t have to go it alone; you can tap into your trusted support network as a source of strength.
Nothing changes if nothing changes. A lot of times it’s easy to get overwhelmed by how you’d like things to change. Taking even a small step in the right direction can be the catalyst for bigger positive changes. Sometimes that takes more courage than you think you have—but showing up that way consistently is what the role requires.
Resilience is learned (both personally and professionally). Few people have had an easy path in life, so give yourself some grace. There will be hard days ahead so stay focused, keep doing the hard work each day, measure your progress, and be honest about the work that still needs to get done.
Sometimes as ethics and compliance folks, we can be a little self-righteous and think we know what is best. But humility is essential as is being prepared to learn from the business and employees. And if some days, it feels like too much and you have lost all patience and feel like nothing is working, get a good night sleep, take a walk, disconnect, and see how things look the next day. As my daughter once said to me on a Saturday night at 11:30pm as I feverishly worked on an urgent matter, “Mom you are making a choice! This is a choice. … You are not a police officer or a doctor.”. And you know what? She was right. Some of my best ideas have come in those moments where I take a beat and step back to be with my family, be in nature, and remind myself what really matters.
Video games have received a lot of criticism over the years. But for many people, video games have been a therapeutic or cathartic experience as well as a positive social one. What are your thoughts on how a games company like Activision Blizzard helps make the world a better place?
This is one of the things that most drives the people who make games and the people who make up the company. There are so many positives that come from games—connecting with other people being one of the big ones. We saw this ever so clearly during the pandemic. Gaming was one way people connected together, whether it was kids who couldn’t see each other at schools or adults who were simply stuck at home. This can be a hard thing to understand from an outside perspective, but you really need to watch the magic happen for yourself. I get to see that through my kids and their friends, watching these teenagers connect, problem-solve, face challenges, and get through them and laugh and learn speaks for itself.
ABOUT THE EXPERT
Jen Brewer is the Chief Ethics and Compliance Officer for Activision Blizzard King, one of the world’s top computer game publishers. Jennifer assumed the role of CECO in 2022 and has been with the company for more than 10 years.