David C. Farrell is Vice President, Deputy General Counsel and Chief Compliance and Ethics Officer at Yahoo in Sunnyvale, California. Farrell joined Yahoo in June 2007 as the company’s first Chief Compliance Officer and is responsible for developing and leading Yahoo’s Ethics and Compliance Organization. His responsibilities include: advising executive management and the Board of Directors regarding business conduct and corporate compliance issues; promoting global awareness and consistent enforcement of Yahoo’s ethics and compliance policies; establishing resources for employees to identify, report and resolve business conduct issues; managing global investigations; resolving conflicts of interest; and working with management to coordinate Yahoo’s global corporate compliance initiatives. Read more about Farrell here.
Ethisphere had the opportunity to catch up with Farrell about his Global Ethics and Compliance program.
In a time where Yahoo seems to dominate the headlines, how do you keep the compliance message focused while managing expectations?
We work to ensure that our employees understand our policies and have access to all the resources they need to make the right decision. We emphasize our business objectives and values. The rewarding part of this experience is seeing how well employees respond and maintain our values while keeping focused on carrying out their day-to-day responsibilities.
What is unique about your role at Yahoo?
I had the opportunity to launch the first ever Ethics and Compliance function at Yahoo and it has been a great experience being able to pull it all together and create a resource like this. Things change every day. With such a broad and diverse user base and business, we are constantly preparing for and anticipating what might happen next. Another significant part of my role is that I get to partner with some of the brightest minds in the business and industry; there are content experts across all functions and disciplines and it’s great to collaborate with them and bring innovative ideas to the table.
When you launched the first Ethics and Compliance program at Yahoo, how did you get buy-in from employees?
I did not want to just rely on assumptions made from my previous experience in the industry.
I took a lot of time in the first month to meet and network with employees at various levels throughout the organization. I started with the organizational chart and each time I connected with one person, I left the meeting with three more names. This helped in building my internal network and gaining a broad perspective on the company and its culture, which made getting employee buy-in easy and effective.
I also examined the history of the organization and identified what worked/what didn’t work. I learned more about the company’s culture and how Yahoo employees viewed their responsibilities and commitment to making the right decision. All in all, it was a natural process to get employees involved in the compliance program.
How does having clearly defined roles in a large company create a better corporate culture? A more effective and collaborative environment is created when you know who to call on different issues and having clearly defined roles makes problem solving a much easier process. There’s a lot of coordination and cooperation that comes in to play to identify the right folks who should be looped in on an issue. There are always gray areas and I think that is where we can add the most value by applying our judgment and expertise and pulling in the right resources. Even when people come to us with questions that are not compliance-related, we still can help them identify which parts of the business they need to engage with to get a matter resolved.
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