As global regulations proliferate and become more complex, so too do the challenges of maintaining a high-performing global ethics & compliance program. While no two days are alike for compliance officers, they do face some common risks and challenges. In this podcast, Ropes & Gray litigation & enforcement partner Ryan Rohlfsen is joined by Glenn Leon, Senior Vice President, Deputy General Counsel and Chief Ethics & Compliance Officer with Hewlett Packard Enterprise, to discuss best practices for mitigating risks and meeting global expectations. The podcast covers:
- Striking the right balance between in-house and outside counsel
- Using data analytics to help manage your compliance program
- Practical ways of fostering a positive ethical tone at all levels of the organization
- Managing and mitigating third-party risk
- Staying current with regulatory and enforcement trends around the globe
Click here to listen to the podcast.
Ryan Rohlfsen: Good afternoon. This is Ryan Rohlfsen, a partner with Ropes & Gray in the litigation & enforcement practice group. I’m here with Glenn Leon, senior vice president, deputy general counsel and chief ethics & compliance officer with Hewlett Packard Enterprise. We’re talking today about common risks, challenges and opportunities in running a global ethics and compliance program. Thanks again, Glenn, for taking a few minutes to chat with us today. What does a typical day look like for you in running Hewlett Packard’s global ethics and compliance program?
Glenn Leon: Well, it’s fair to say that there is no typical day – probably all of us could say that about our respective jobs. My team handles the core workstreams we have are investigations, our most serious ethics investigations. We have a separate anti-corruption program. We have a global trade team. We have a privacy team. We also spend a lot of time with policies, training, running our mailbox and our open door policy. And then we also have a separate, what we call, a SER program, a social and environmental responsibility program. At a high level, that’s what my team does. I would say I spend certainly the majority of my time focusing on anti-corruption issues and investigations, and less so perhaps on a day-to-day level on some of the other issues.
Ryan Rohlfsen: So Glenn, where would you say you’re spending a majority of your time and resources right now in terms of mitigating risks for the company? And how are you tackling it?
Glenn Leon: A few areas. We are spending a lot of time on training. We’re actually in the process right now of reviewing our SBC, our standards of business conduct – it’s a very good product. It hasn’t been revised in five years and we’re making it better. We’re making it more targeted to our particular areas of risk. We’re making it more readable. We’re making it more interactive. So training, communications is a big priority of ours. Anti-corruption, FCPA is a big area of risk, so we do spend a lot of time auditing our anti-corruption programs, auditing our partners as appropriate, making sure that the various systems that we have in place in-house can improve. We’re always looking for areas to improve in our anti-corruption space – that’s another big area.