I think we have that in several ways. One is we had a big FCPA settlement and that gets a lot of people’s attention. And frankly, you know, I think we took advantage and made the most of a bad situation, so I can truly say we have the buy-in of the people who really run the company, so that’s kind of point one. Point two is we have various measures that are in place where we get engagement with the business, not just legal but business, HR, finance, and legal. So we have in addition to regular contact with the audit committee, we have a separate ethics and compliance committee – that’s a separate committee that I chair. It has many members of the executive committee, many members who report, business leaders who report to the CEO. And I meet with them once a quarter and I talk to them about trends, issues, key investigations, remedial efforts, things like that. That’s another way to keep engagement tone at the top. We have other systems in place where we have very regular contact with key business leaders to let them know about issues, trends that we’re seeing. So that’s not just tone at the top, but then to your other part of your question, tone at the middle. I’ve got two calls, for example, scheduled next week with a group of people who we call liaisons. Those are people who are more senior level middle managers who are particular leaders in the regions in particular countries. And we’re going to sit with them, two different calls for an hour each, and talk to them about investigations we’re engaged with, remedial efforts, trends, positive and negative, and getting direct engagement with them. Another thing I’m going to be doing, I’m going to be flying around the back end of this year with several leaders of mine, my other directs, to go and do face-to-face training. Go to countries, go engage with business leaders really at that more middle manager level to let them know what we’re seeing, want to hear what they’re seeing, and have very frank conversations. And those are just some examples I have when we’ve engaged at the tone at the top as well as tone at the middle.

privacy laws
Order Now on customessaymasters.com