“We only want clean business, and if we do not get clean business, we won’t take it.” That is what executives at his new company told Andreas Pohlmann, CCO, SNC-Lavalin Group, Inc. This, he says, is a perfect example of “tone from the top.”

Daniel Trujillo, SVP and International CCO, Walmart, pointed out that the word “crisis” comes from the Greek for decision, and noted that Walmart has, since its inception, has focused on making the right decision.

These were the opening remarks at the second keynote session at the sixth annual Global Ethics Summit. The topic was “Lessons from a Crisis” and the two chief compliance officers shared their experiences with crises. 

One issue that arises after a crisis, Pohlmann said, is determination if misbehavior is systemic or the result of just a few bad apples. He reemphasized the importance of tone at the top, and stated that rooting out the cause of the specific crisis is key. He noted that communication and training are important, helping ensure that all of the global arms of a large corporation are on the same page when it comes to ethics and compliance. In-person training is better than remote training, he stated, because this allows the compliance team to see firsthand that people understand the message clearly.

Trujillo spoke about the opportunity to closely examine a compliance program in the wake of a crisis. He stated that, after a crisis, he had a chance to look at the business and the potential problem points, taking a holistic approach and structuring a global program based on what was working in different silos. Identifying goals, such as creating a risk-based approach and sustainable processes, led the development of the program.

“Understanding the company and understanding the culture,” is essential, Trujillo says, adding that making sure the tone at the top goes throughout the organization. Both he and Pohlmann acknowledged that, no matter what procedures you put in place, problems can occur, so it’s a matter of discovering the issues and dealing with them as soon as possible is key. They both stated that knowing the business inside and out is foundational for any compliance program.

When asked “what goes wrong most often,” Trujillo opined that one needs to understand what can go wrong in your company, because it varies so much based on the industry and organization, though getting management to ask that question is a good first step toward ameliorating issues. Pohlmann, speaking generally, emphasized the fact that lack of tone from the top can be fatal, as can ignorance of business partners, lack of training or communication among business units and willful blindness toward actions of partners.


For more on ethics, check out the following:


Finding the appropriate balance between ethics and compliance in a regulatory landscape

10 crucial first steps for the chief compliance officer

Inside: Remember, your client is the corporation, not executives