FedEx, WSP, AECOM, and SABIC share their best practices
Throughout the year, Ethisphere’s Data and Services team conducts full program assessments for companies looking to benchmark against our Ethics Quotient® (EQ) data set and have our experts conduct an analysis of the program and corporate culture in six key areas: Program Resources and Structure; Perceptions of its Ethical Culture; Written Standards; Training and Communication; Risk Assessment, Monitoring and Auditing; and Enforcement, Discipline, and Incentives. Those with outstanding programs are recognized with Ethisphere’s Compliance Leader Verification.
At Ethisphere, we like to share leading practices with our broader community so that all may learn. Here are highlights into top programs from longer Spotlight Q&As that can be found in the Resource Center on Ethisphere.com.
FedEx: Mitigating Ethics and Compliance Risks Across a Global Organization
Justin Ross, is Staff Vice President and Chief Compliance Officer for FedEx Corporation. FedEx provides customers and businesses worldwide with a broad portfolio of transportation, e-commerce and business services.
Historically, each of FedEx’s subsidiaries handled compliance at the local level. In 2015, FedEx centralized its corporate compliance program to provide more structure and transparency, and better align on priorities, risks, and resource allocation.
The central corporate compliance team, referred to as Corporate Integrity &Compliance (CIC), reports up through the General Counsel. As Chief Compliance Officer, Ross also updates the board of directors on a regular basis. In turn, the local compliance teams at the FedEx business units and international regions have strong partnerships with CIC. Ross and his team have been intentional about creating a strong governance framework across the enterprise, providing training, aligning on enterprise compliance initiatives, and sharing best practices to empower these local compliance teams.
“Structurally, our business units have made real progress over the last five years,” Justin says. “We provide subject matter expertise on compliance areas within their responsibility, and they’ve become more independent.”
Another way that CIC engages across the organization is through the Compliance Council. This enterprise-wide group meets every quarter and includes members from the corporate team, business units, international regions, and a diverse range of functions including HR, communications, security, and internal audit. The Council discussions cover emerging risks, investigations results, and new initiatives and serves as an important venue to spread best practices.
“It’s been a great forum for us to educate our international compliance teams, and also learn about successful initiatives that we share around the enterprise,” Justin says.
WSP: Elevating Ethics and Compliance as a Key Strategic Business Partner
Julianna Fox is Chief Ethics and Compliance Officer for WSP, a leading professional services firm providing engineering and design services to clients in the Transportation & Infrastructure, Property & Buildings, Earth & Environment, Power & Energy, Resources and Industry sectors.
For most companies, ethics and compliance is becoming increasingly integral to corporate strategy. WSP has worked to elevate the status of the team and its leaders to that of strategic business partners with the rest of the enterprise.
“We’re very proud of how our program has evolved over the past five years,” Julianna says. “We’ve really been able to transform our ethics and compliance function into key strategic business partners. The team not only does training, implements controls, and monitors; they’re also part of the executive level strategic decision- making process. It’s been quite exciting to see that evolution.”
It can be a struggle to gain support from the executive leadership team. For WSP, the ethics and compliance team has been intentional about having rich conversations with leadership to get them to understand why the program is important, what is being done, and what risks they are tackling and mitigating.
“We’re privileged by the tone that our leaders have for ethics and compliance. They’re truly people that understand “the why” behind an ethics and compliance program. Once you have that understanding, it’s much easier to get their buy-in and engagement to promote the program and support the ethics and compliance team across the organization,” Julianna says.
“Our relationship with management enables us to embed ethics and compliance communications into the organizational dialogue, including the messages from the CEO and senior management.”
AECOM: Insights into Building a Leading Ethics & Compliance Program
Antonio D’Amico is Senior Vice President, Deputy General Counsel, Chief Ethics &Compliance Officer at AECOM, a global infrastructure consulting firm.
Antonio explains that at AECOM, the senior leadership are vocal proponents of the ethics and compliance program, which in turn helps Antonio’s team engage with stakeholders across the organization.
“In addition to discussions I have with leaders about ethics-related issues that come up, we also hold a quarterly Global Ethics and Compliance Committee (GECC) meeting with our executive leaders,” Antonio says. “The GECC is co-chaired by our CECO and Chief Legal Officer and includes our CEO, President, CFO, and group operational and functional leaders. The quarterly meeting gives us the opportunity to share, among other things, program updates, investigation statistics, training completion rates, and program and risk assessment findings.”
Antonio’s team also holds a monthly ethics call with functional leaders from Legal, HR, and Audit to provide a venue to share regional updates, discuss open investigations, and review hotline statistics with our legal and HR colleagues.
SABIC: How To Advance an Ethics and Compliance Program
Bo van Zeeland is GM & Chief Counsel Compliance &Litigation at Saudi Basic Industries Corporation (SABIC), a global diversified chemicals company headquartered in Saudi Arabia.
Please tell us a bit about your program and how it has evolved over the past several years.
SABIC’s Ethics and Compliance team balances a global mission—engaging the business in building and maintaining a world-class compliance culture-with local execution.
The team is part of Legal Affairs and comprises 20 members working on policies, program initiatives, training, tools, and investigations. It works with trained commercial attorneys (and other functions such as HR) to conduct compliance concern investigations, training, and program support in several regions.
For the Middle East & Africa region, SABIC has a dedicated investigation team for compliance concerns. In addition, the company has more than 150 business ethics champions, called “Integrity Ambassadors,” across all of its key locations. They conduct training, provide guidance, and facilitate reporting of compliance concerns. The program has grown steadily to meet emerging compliance and regulatory needs—most recently with an elevated Data Privacy Program and initiatives to support SABIC’s ESG profile and reporting.
“We are very proud of our network of business ethics champions. They effectively provide us with local ‘eyes and ears’ on integrity and compliance issues at our key locations and help to ground our program. They conduct speak-up awareness training sessions and facilitate concern reporting,” Bo says.
“When setting up a program like this, we believe that it is important to ensure objective selection criteria, conduct discrete background integrity checks with your HR department, and ensure visibility and recognition by executive management. You have to enable them with tools and training (such as a train- the-trainer program) and ensure that you are not over-asking on their commitment. It’s really important and most effective to encourage them and ensure with management that they are recognized and rewarded for their contributions.”
About the Author
Anne Walker is Vice President of Media & Communication at Ethisphere.
