What do ethics have to do with compliance? Gillian Paul, Global Integrity Director for Danone, believes that businesses that have a clear vision of ethical standards at the C-suite will ultimately have a successful understanding of how compliance filters down throughout the company and how it impacts business performance.
In our podcast conversation, Gillian and Steve Muddiman discuss how to embed that understanding in an effective way. She shares why taking time to understand the challenges in your colleagues' businesses, as well as the different situations around the world, can have a profound impact on how compliance has to change and adapt in a digital world.
Gillian has been at Danone for over sixteen years, working in different business units and countries, and spent the majority of those sixteen years in a commercial rather than a compliance role. Five years ago she decided she wanted to make a difference to the way Danone did business, to make a difference, to make the world a fairer place; to play her part. To use her words: ‘When you’re in a compliance and ethics role you can talk about wanting to play your part in making the world a better place.’
Culture and Ethics
Danone is a world leading food company; the mission is to bring healthy food to as many people as possible. This is facilitated by the geographical spread of the business. From a cultural perspective, the tone is set from the top. Gillian’s stance is that if you have a very strong chief executive who is very clear on the ethical standards that they want to operate by, then that filters down more efficiently within the organization. Danone’s culture is founded on openness, humanism, collaboration and is relatively flat, which allows employees to speak up and raise problems which need solving. ‘Compliance has to be part of the business’ she said and added ‘not an afterthought but fully embedded in the overall business processes.’
At a company selling essentials, like Danone, the culture communicates that compliance is simply about how the company does business by ensuring the sustainability of what the company does. This gives compliance a fantastic platform to work from.
Compliance and Commerce
During the interview, Gillian argues that regardless of their backgrounds, compliance officers have to understand the business that they’re in and the challenges faced by their colleagues around the world. This way they can work with them to design an effective program. This requires engaging with procurement or treasury teams to understand their decision-making process. Gillian has a unique advantage in having worked in different business units and countries which has allowed her to see this. Gillian also works with audit, internal control and lawyers with both internal and external experience. They all bring a different perspective to the table which allows compliance to get under the skin of the business and design solutions which are effective.
Perceptions of Compliance
Compliance has historically been about rules, about policy. Gillian sees it as being more than that. It’s about behaviors, it’s about governance; the majority of people want to do the right thing and the role of compliance is to show them what the right thing is. This could include considering cultural norms in different parts of the world or just thinking two steps ahead of the situation and its implications.
Having worked in Sales, Gillian has seen how easy it is for ethics to play second fiddle to the pursuit of quick profits, as has played out in countless news stories. Fundamentally though, people want to buy from people, and they want to buy from people with a similar value system to them. This takes compliance beyond rules and regulations, incorporating ethics into business processes rather than imposing a rulebook which may or may not be read. To use Gillian’s words: ‘If you can get beyond rules and policy, you make it simple and effective, you start to win hearts and minds.’
A strong tone from the top is critical. The compliance world is unrecognizable from where it was even ten to fifteen years ago where the C-Suite were generally not putting much thought into it. The mood around the world and from different governments has transformed the corporate approach to ethics and the focus on sustainability, simplicity and effectiveness has helped Gillian drive that cultural change. She says, ‘I think we have on the one hand the most amazing job in the world but an incredibly challenging job because every day we are change agents driving that forward.’
The new tranche of Russian sanctions issued by the US Government are a prime example of the kind of challenges compliance professionals are faced with. Gillian says that as a company selling things like yoghurt, water and nutritional products, Danone is not necessarily used to dealing with export controls or supply restrictions. This has been a learning curve for everybody from procurement to supply chain teams. Similarly, the pandemic has necessitated having compliance at the front and centre of the business, and not just in the EU. ‘You won’t know the answer to every question but you need to know where to get the answer, and get the answer quickly,’ she says, reiterating the fact that as compliance professionals this means you have to be able to act quickly. You have to be accessible.
Gillian stresses the importance of technology. A lot of thought goes into the tools compliance might need and operating on excel or on paper is often not enough at large organizations. There are systems in place to monitor learning, due diligence, digital document signing, integrations and interactions between systems, and a whole host of other effective platforms. Compliance works closely with the IT team at Danone and collaborates to create the kind of simplicity which makes compliance just a part of doing business, rather than an additional step. ‘Just make it a part of the process,’ she argues.
The Future of Compliance
Compliance currently screams of rules and procedures, says Gillian. The role of compliance is, however, to drive corporate activity forwards in an ethical way. The days when it was a competitive disadvantage to abide by compliance are over, it will now be a competitive advantage. Compliance will no longer be about reading external rules and procedures but will be about learnt behaviors. Children and adults alike learn most through doing and that’s what the future of compliance will be guided by.