The accolade, in its second year, recognises the tireless efforts and dedication of E&C professionals who are leading the charge to embed integrity and ethics as a core value within their organizations.

Nominated by the Ethics and Compliance and Vault Platform community, these individuals stand out as the movers and shakers of the ethics and integrity space.

The 2024 Integrity Innovators

– Amy Mertz Brown, Chief Compliance and Privacy Officer, Boeing Employees Credit Union 

– Laurel Burke, Chief Ethics & Compliance Officer and In-House Leader, Axiom

– Candace Ciresi, Chief Compliance Officer, Mobileum

– Sam Craft, Global Director, Compliance Training and LMS Management, Alcon

– Claudia Curtis, Senior Vice Presidents, Chief Ethics and Compliance Officer, BD

– Rupert Evill, Founding Director, Ethics Insight

– Linda Frazier, Chief Compliance Officer, TripAdvisor 

– Adam Hunt, Leader (Senior Director) of Global Ethics and Compliance Org, Netflix

– Ellen Hunt, Principal Consultant and Advisor, Spark Compliance Consulting

– Sandhya Sharma Global HR Program Manager, MiQ 

– Joseph Philipose, Senior Vice President, Chief Ethics and Compliance Officer, Emergent Bio Solutions

– Gitanjali Sakhuja, Fractional CCEO, GS Consulting

– Carolina Santos da Silva, Head of Ethics & Compliance EMIA, Bridgestone EMIA

– Sonja Sefrin, Associate Director, Ethics, ING

– Micheal Sheely, Chief Compliance Officer, Payoneer

– Monica Thurman, Director, Ethics and Legal Compliance, Intel

 – LaSalle Vaughn, Chief Compliance, Ethics & Risk Officer, Bestow

– Hitomi Walter, Legal Compliance Lead, Wellcome Trust

– Emma Williams, Director of European Risk & Compliance MLRO, Simpson Thacher & Bartlett LLP

Promoting Active Integrity

At Vault, we believe that companies must be active in their pursuit of flawless integrity. And Vault’s core value – promoting Active Integrity – is at the heart of what Integrity Innovators is all about. 

Everyone selected embodies this value, and exemplifies a commitment and vision to make work a better place for everyone.

Their endeavours are serving as inspiration for the next generation of Ethics and Compliance leadership, showing that integrity is not just a buzzword, but a fundamental principle that shapes organizational culture and success.

Our Innovators have also been earmarked as thought leaders in their field, the ones to watch for the latest trends. 

In coming weeks we will hear from them about the projects they’re most proud of, their vision for creating better ethics programs, and their thoughts on the hot topics within the profession.

Meanwhile, if you’d like to find out more about how innovators are building active speak up cultures in their organizations, get in touch.

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One of the biggest miscarriages of justice in Britain’s history, the Post Office Horizon IT scandal has rocked the country, with recent revelations catapulting the saga to center stage in the media spotlight.

An ITV drama brought to life the astonishing accounts of hundreds of innocent people whose lives were ruined after incorrect data from Fujitsu’s faulty IT system had wrongly suggested they stole money. 

The TV programme captured the public imagination and sparked huge national outcry, applying pressure on politicians to act and move forward with proposed new laws to quash the wrongful convictions of hundreds of innocent Post Office sub-postmasters.

Around 900 were prosecuted and more than 200 sent to prison from 1999 to 2015. 

It’s taken a very long time for the truth to surface. But would it have ever emerged without whistleblowers?

The critical role of whistleblowers

The role of those with inside knowledge of what was really happening behind the scenes has been cited as crucial, alongside the incredible efforts of campaigners.

Whistleblower Richard Roll’s crucial contribution in unveiling the truth about the flawed Horizon software was highlighted in the TV adaptation. His testimony was key in the 2019 High Court Case, which helped prove the innocence of many victims.

An ex-Fujitsu engineer, he was part of a team who had access to Horizon terminals remotely. He’s been giving evidence to the ongoing Public Inquiry in recent weeks.

Mr Roll went on camera in 2015 to tell the BBC’s panorama what had happened behind the scenes.

The challenges of speaking up

The dramatisation showed the difficulties for a potential whistleblower of speaking up. It highlighted the fears and anxieties that come with going up against such large organisations.

And as the full details continue to emerge in the glaring spotlight of the ongoing inquiry, further startling revelations emerge.

More whistleblowers have come forward – with the latest via the Guardian newspaper regarding possible destruction of evidence that might have cleared wrongly accused victims.

How could things have been different?

UK Prime Minister Rishi Sunak,  The Criminal Cases Review Commission, and even the Post Office itself, have described the scandal as one of the greatest miscarriages of justice ever seen in Britain.

Could it have all been prevented before it escalated to this stage?

It’s not clear if misconduct reporting systems were in place within the organisations at the centre of this case at the time. But Mr Roll, in his written evidence, describes certain problems being “hushed up” by managers at Fujitsu during his time working there. 

Mr Roll blew the whistle years after leaving the company by going directly to campaigners.

Hugely damaging for businesses

The enormity of the scandal that has engulfed both the Post Office and Fujitsu is unquestionable.

It illustrates that businesses can easily have blindspots to potentially disastrous headline-grabbing business risks. 

The reputational damage is likely to be gigantic, analysts have said.

Fujitsu Europe Director Paul Patterson acknowledged the damage to the firm’s reputation when speaking to UK MPs recently, as he issued a company apology.

Then there’s the financial implications, with compensation claims in this case still far from resolved but estimated at more than £1bn.

The saga offers a sobering case study for all modern day organisations who aren’t actively seeking to uncover risks and misconduct at source.

How can other brands avoid such a scandal?

One study from The US Equal Employment Opportunity Commission estimated up to 75% of workplace misconduct is never formally reported.

And an Ethisphere research paper found nearly half of employees who observed misconduct in the past 12 months failed to report the matter.

So, there could be many problems bubbling under the surface that organisations are not being made aware of.

For companies seeking to avoid a scandal like the Post Office, the key is to uncover wrongdoing and risks early before they escalate into something far larger. 

Developing an advanced Speak Up culture

To achieve this requires developing an advanced Speak Up culture within the business, empowering employees to report misconduct. And backed by a robust misconduct reporting solution.

Traditional one-size-fits-all channels – like legacy hotlines are not fit for purpose and most incidents are either not reported or surfaced through anecdotal feedback.

Businesses risk compliance failings if processes to surface concerns, investigate cases and report progress are not connected and the workflows are inefficient. Instilling a modern, sophisticated, fully equipped modern case management and whistleblowing system is essential.

It empowers everyone in your ecosystem – investors, employees, vendors, customers – to help you uncover unreported incidents, contribute to resolving them faster and enable you to prevent future wrongdoing. 

How can Vault help?

We believe companies can be protected from major risks – perhaps the next big crisis scandal or lawsuit – if their people are protected too. Our platform delivers the true opportunity to Speak Up.

Uncover risks early by: 

– Enabling the people in your ecosystem to gain access and speak up about incidents by offering multiple reporting channels, including the mobile app and Vault Talk, our AI-powered hotline.

– Capturing actionable insights (rather than unstructured reports) that lead to credible investigations through tools that make reporters feel psychologically safe, including anonymous reporting.

Book a call with one of our specialists to find out more.

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Wavering trust

Our Trust Gap survey demonstrated that a rift exists between employees and employers which is costing US businesses $20 billion a year on rehiring alone. It also revealed that a third of workers believed their organization would brush aside workplace misconduct if it was likely to impact profits or reputation and that 63% of workplace misconduct incidents are never reported.

Zendesk’s Hemma Ramrattan Lomax said: “One of the biggest challenges for businesses will be instilling and maintaining trust with a workforce that is insecure and burned out, especially in the tech sector, with recent layoffs and hits on revenue and stock prices. It’s important for E&C professionals and leaders to decide how we can best support our colleagues when they’re asked to do more with less.”

Adam Balfour from Bridgestone Americas added: “Trust levels are low and stakeholder expectations of organizations are increasing. While this is a significant challenge in 2023, it’s also an opportunity to really focus on being trustworthy, taking ethics and compliance seriously, and being a purpose-driven and people-focused organization.”

Organizations today need to continue to place a significant focus on trust, considering carefully how they build and maintain it with employees, shareholders, customers, suppliers, and the world at large. Read more about the importance of rebuilding trust in our recent blog post.

Changing expectations

As Hemma alluded to, recent layoffs in the tech industry have many people worried about job security. Moreover, conscious quitting has been making headlines as more people choose to work for organizations that better represent their personal values. Organizations yet to truly understand just how crucial it is to build and maintain their workforce are falling behind while others that are actively choosing to align their values with those of the people in their ecosystems thrive.

Fraser Simpson from the Wellcome Trust said: “We’re focusing on humanising what we’re doing and truly embedding our process of engaging mindsets through storytelling and role-modeling, sparking conversations, and providing access to simple tools for changing behaviours and habits in the moments that matter.”

Similarly, Kevin Withane from TI Fluid Systems said: “We’re maintaining momentum and traction in our efforts to build a culture of ethics and make headway in keeping colleagues engaged.”

Another consideration for worldwide businesses is how to ensure policies and initiatives are both standardized and yet localized. Billy Hughes from Victoria’s Secret said: “After a few years of restricted travel due to the pandemic, I’m excited to get our team back into the field, visit more of our global offices, and find innovative ways to better localize our programs.”

Political divides and legislative changes

There has been a backlash in recent months, primarily from Republicans in the US, against the environmental, social, and corporate governance (ESG) investing movement. However, executives say ESG Is here to stay.

Rob Chesnut said: “ESG shouldn’t be partisan – the biggest challenge is to help keep ESG from being dragged into our fractious politics. We can disagree about what ESG may mean for different companies with different cultures in different sectors, but we all should be aligned in the belief that companies have an obligation to stakeholders beyond just their investors.”

Meanwhile, Anna Romberg, co-founder of the Nordic Business Ethics Network, foresees a tsunami of ESG-related regulation in the near future.

And ESG isn’t the only area in which our Integrity Innovators predict major legislative changes. Jennifer Lane, a former federal prosecutor, highlighted The Department of Justice’s recent settlement with Meta, which set a new standard for addressing discrimination through machine learning, as well as the significant changes made to the Criminal Division’s Corporate Enforcement Policy.

Similarly, Lloydette Bai-Marrow said: “The likely changes to corporate criminal liability in the UK will be a significant challenge for organizations, not to mention the use of artificial intelligence in the E&C field.“

It’s clear that forward-thinking businesses must ensure they remain up to date on and compliant with any relevant changes in ESG legislation regardless of politics.

Moving away from reactive mitigation

When it comes to dealing with issues of workplace misconduct, businesses can no longer afford to take a reactive approach, which involves mitigating incidents rather than active prevention.

Alison Taylor, Executive Director at Ethical Systems said: ”We must reinforce the importance of integrity despite the political backlash and continuously improve the Speak Up culture we’re creating. We need to continue to provide employees with assurance that action will be taken where necessary and that a healthy Speak Up culture works hand in hand with a healthy company culture.”

Aura’s Ling-Ling Nie said: “Some people think that a high-growth culture and a compliance culture cannot co-exist in a productive way. But I am always up for a challenge and will continue to cultivate a healthy ecosystem where both can thrive.”

Jennifer Lane added: “We’ve designed our compliance program to go above and beyond what the law requires. From prevention and detection to our response to reports of misconduct – our perennial challenge is to continue to innovate, with data-driven systems and standards that incentivize accountability.”

Check out our Active Integrity: A New Code of Ethics for Forward-Thinking Businesses ebook to find out more about the benefits of Active Integrity.

The post Major hurdles facing E&C professionals and how to overcome them appeared first on Vault.

Housed in NYU Stern’s Business and Society Program, Ethical Systems uses research-based strategies to help transform the ethical practices of the corporate world through trust, integrity, and collaborative research. By working directly with companies to address cultural challenges, Ethical Systems is helping to raise the bar for corporate ethical standards.

Along with her colleagues and industry collaborators, Alison is moving corporate ethics and compliance forward, leading the next generation of ethical businesses toward effective cultures.

This year, Alison is hoping to wrap up her book on how businesses can do the right thing in a turbulent world. She said: “One of the biggest challenges and opportunities for the corporate compliance world this year is how we collectively reinforce the importance of integrity in business despite the huge political backlash.”

When it comes to inspirational peers, Alison cites Denise Hearn’s work on economics and Tessa Wernink’s work on employee activism. Alison is also a huge inspiration for others and was the most referenced nominee amongst our other Integrity Innovators in the field.

Always thought-provoking with her examples of good and bad corporate ethics, Alison is a true torchbearer and an excellent advocate for innovation.

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1. Reporters Are Choosing To Speak Up

The SEC’s Whistleblower Program received more than 12,300 whistleblower tips in 2022 – a new record. This speaks to the willingness of today’s workforce to Speak Up when they experience or witness misconduct and of the growing pressure on companies to listen to their employees.

The SEC issued approximately $229 million in 103 awards, making 2022 the SEC’s second-highest year in terms of dollar amounts and number of awards. This dollar value indicates just how important whistleblowers and the tips they provide are to the SEC. Organizations should be demonstrating the value of their employees’ willingness to Speak Up too by putting in place safe and accessible internal reporting channels and processes so that they hear about business risks from their employees directly. They can then safeguard against reputational damage and other business risks.

2. Retaliation Will Not Be Tolerated

People are also more willing to Speak Up because the SEC safeguards their anonymity and protects whistleblowers by pursuing individuals or entities who take steps to impede or retaliate against them. Enforcements such as those against the Brink’s Company and the co-founder of a technology company send a clear message that retaliation against whistleblowers will not be tolerated. 

Anonymity is an important consideration for internal reporting channels too. Handily, Vault Platform is designed to provide a safe space for employees to report issues either anonymously, in name, or through the power of strength in numbers (more on this below). Discover how you can combat retaliation in your organization.

3. Individuals Are Held Accountable

Individual accountability is stated as one of the pillars of the SEC’s enforcement program and more than two-thirds of the stand-alone enforcement actions involved at least one individual defendant or respondent in 2022. The SEC even charged several executives under Sarbanes-Oxley (SOX) 304, and ordered them to return bonuses and compensation following misconduct at their firms.

Of course, there are ways companies can mitigate against failure to take action and concerns being ‘brushed under the rug’. For example, Vault’s unique time and date stamp technology provide real-time audit logs to demonstrate concerns have been received, investigated, and resolved.

When it comes to identifying culpable individuals internally, Vault’s GoTogether® feature enables employees to surface a report under the condition they’re part of a pattern, including when another Vault app user in their organization names the same specific individual as an alleged offender. You can then identify any ‘bad apples’ within your organization and take meaningful action, dealing with the issues internally before they grow.

4. The Risks Of ESG Violations

Investors are increasingly interested in environmental, social, and governance (ESG) matters and the threat of ESG violations. A portion of the SEC’s 2022 enforcement was therefore dedicated to these issues with respect to public companies and the accuracy of their disclosures. For example, enforcement actions were taken against BNY Mellon Investment Adviser, Inc. for misleading statements and omissions about its consideration of ESG principles in investment decisions. An investigation into Vale S.A. – one of the world’s largest iron ore producers – revealed that it had misled local governments, communities, and investors about the safety of its dams prior to the collapse of the Brumadinho dam in Brazil, which killed 270 people and caused serious environmental and social harm. If you’re keen to further develop your organization’s ESG strategy and prevent violations, download our ‘ESG Do’s and Don’ts’ ebook.

5. Behaviors Need To Change

One of the key takeaways from the SEC’s results is that while records have been broken in terms of the number of tips received and awards given, this shouldn’t become the norm. Penalties are a deterrent; a way to demonstrate how seriously the SEC treats incidents of misconduct and to set the bar for the workplace of the future. 

Gurbir S. Grewal, Director of the Division of Enforcement, said: “While we set a Commission record this past fiscal year for total money ordered at $6.4 billion, including a record $4.2 billion in penalties, we don’t expect to break these records and set new ones each year because we expect behaviors to change. We expect compliance.”

Looking for an all-in-one system of record where misconduct reports can be safely captured, tracked, and resolved internally? Book a demo today.

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In this blog post, we suggest ways your business can meet the DOJ’s expectations and elevate your ethics and compliance (E&C) programs to truly deter wrongdoing beyond simple compliance.

Heed The Call

Deputy Attorney General Lisa Monaco’s remarks came on 15th September 2022 at a New York University event. As part of her wider policy announcements, she called for corporations to disclose in a timely fashion relevant facts and records about all potentially culpable individuals involved in misconduct. 

There are two significant parts to this call worth delving into; i) both companies and individuals will be held more accountable for workplace misconduct and ii) the speed at which misconduct is resolved and reported to the DOJ. Bad apples can exist in any organization but it’s how they’re dealt with and how quickly your organization reacts that really matters to the DOJ.

i) Rooting Out Problems

If your organization not only wants to comply with the DOJ’s plan but also set industry-high standards for business integrity, it must have efficient policies and programs that get to the root cause of misconduct.

When it comes to identifying culpable individuals, Vault’s GoTogether® feature enables employees to surface a report under the condition they’re part of a pattern, including when another Vault app user in their organization names the same specific individual as an alleged perpetrator.

Even if specific individuals aren’t named as perpetrators in misconduct reports, ethics and compliance professionals can use the data available in Vault’s Resolution Hub to spot trends and identify high-risk areas. It may be that there are specific departments where incidents occur more often, for example, or specific types of misconduct that are more prevalent. It’s then up to case managers to investigate and take action based on their findings.

ii) Time For A Change

Monaco urged organizations to report misconduct to the DOJ quickly and made it clear that penalties will be enforced on those that don’t turn over information fast enough.

Modern resolution platforms like Vault offer organizations insights that can drastically reduce the time between report submission and resolution. When data is decentralized, such as when it comes from incumbent solutions and spreadsheets, it makes data gathering and analysis a time-heavy nightmare. Audit logs need to be created manually, which leaves a lot of room for oversight and manual error. Vault on the other hand centralizes all data and allows you to export audit reports from within the Resolution Hub. This in turn speeds up the process of reporting to the DOJ, meaning your organization remains fully compliant and is able to demonstrate its commitment to proactively tackling misconduct, all in a timely fashion.

Rewarding Transparency And Honesty

According to a U.S. Sentencing Commission report, the number of guilty pleas by corporations has trended downward from a high of 304 in 2000 to just 90 in 2021. Coupled with this is the overall decline in corporate criminal prosecutions over the last decade, which Monaco called out. She added, “We need to do more and move faster.”

The memo issued alongside Monaco’s announcement directs enforcement sections of the DOJ to develop policies that encourage companies to voluntarily disclose misconduct. Organizations should be prepared to discuss their full record of past criminal and regulatory misconduct when resolving a case with the DOJ. Those that choose to disclose incidents of misconduct to the DOJ willingly will be eligible for deferred prosecution agreements. Critical to Monaco’s plan is encouraging organizations to be more honest and transparent with their misconduct reporting.

This extends into the preservation of communications as well. Firstly, compliance leaders must ensure the DOJ’s new approach to compensation is communicated internally. Secondly, they must establish effective policies to ensure that business-related information communicated on personal devices and third-party messaging platforms is preserved. “Cooperation credit” will be given to organizations that can collect and provide non-privileged information relevant to the investigation.

Handily, Vault facilitates communication between case managers and reporters and the uploading of documentation, such as copies of any communications from third-party channels. E&C teams can then keep track of all case materials and communications relevant to the case within the Resolution Hub and provide these to the DOJ as evidence for any ongoing investigations. 

A Picture Of Health

The DOJ’s announcement makes it clear that organizations can no longer sideline their compliance commitments or continue with ‘business as usual’. They must show that they are reactively and proactively dealing with all forms of misconduct at all levels.

The key takeaways are that organizations need to aid any ongoing DOJ investigations and ensure that ‘bad apples’ – regardless of seniority – are dealt with appropriately. Speed and transparency are essential, as is easy access to as much historical and ongoing case information and data as possible.

Above all, your organization should aim beyond compliance to really stand out from the crowd. Taking a leading stance in the ethics and compliance space can help to differentiate your organization from competitors and ensure that you make headlines for the right reasons when DOJ investigations become public knowledge.

The post Evaluating The Health Of Your E&C Programs In Light of the DOJ’s Announcements appeared first on Vault.

The elements of shift cover four areas of practice guidance and call on companies to revise their compliance frameworks.

(I) Individual Accountability 

Holding individuals who commit and profit from corporate crime accountable deters future illegal activity and promotes the public’s confidence in the justice system.

A. To allow adequate investigation and seek appropriate criminal charges against individuals, corporations must disclose in a timely fashion relevant facts and records about all potentially culpable individuals involved in misconduct.

B. Going forward, prosecutors must determine whether there is a significant likelihood that the individual will be subject to effective prosecution in other jurisdictions before prosecuting in the United States.

(II) Corporate Accountability

A. “Not all instances of prior misconduct are created equal”. In determining how best to resolve an investigation, prosecutors should consider the corporation’s history and record of past misconduct and give it due weight. Monaco discusses the approach, addresses a range of factors, and outlines additional guidance for corporate recidivism evaluation.

B. DOJ will reward companies that voluntarily self-disclosed (VSD) wrongdoings and would not pursue indictments or seek guilty pleas of corporate wrongdoings absent aggravating factors. For the first time, Monaco called those sections in the DOJ that have not yet adopted a clear and predictable VSD-incentivizing program to do so.

C. Level of a corporation’s cooperation can affect the form of the resolution, the fine, and the undertakings.

D. We all know that an effective compliance program and a strong ethical and compliance culture may have a significant impact on resolution terms. Monaco presented additional new metrics relevant to prosecutors’ evaluation:

1. 1. Companies should demonstrate that the principle of shifting the burden away from shareholders to those (employees, executives, or directors) who either directly or through supervisory actions or omissions contributed to misconduct is reflected in their compensation systems and exercised in practice. The next Blog post in this series will extensively discuss the expansion shaping in the DOJ and SEC approach to holding corporate leadership more accountable to misconduct.
   2. Companies must ensure that business-related information communicated on personal devices and third-party messaging platforms is preserved.

(III) Independent Compliance Monitorships

A. The need for a monitor and its scope must depend on the facts and circumstances of a particular case. When evaluating the necessity and potential benefits of a monitor, prosecutors should refer to the (non-exhaustive list of) factors detailed in the memo.

B. In selecting a monitor, prosecutors should employ consistent and transparent procedures.

C. Continued Review of Monitorships.

IV. Commitment to Transparency in Corporate Criminal Enforcement

Transparency in the department’s work is important to encourage companies to adopt compliance programs, voluntarily disclose and cooperate in investigations. The memo outlines the desired scope of corporate criminal resolution agreements and determines that it will be publicly published.

This is the first post in an ongoing blog series as we take an in-depth look at the most critical elements of the DOJ’s announcement.

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