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Evolving from a Check-the-Box Function to a Culture of Compliance

Home > Perspectives > Evolving from a Check-the-Box Function to a Culture of Compliance

The U.N. Office on Drugs and Crimes estimates that annual illicit proceeds total more than $2 trillion globally. Proceeds of crime generated in the United States were estimated to total approximately $300 billion in 2010 or about 2% of the overall U.S. economy. As history would remind us and amidst the COVID-19 pandemic, crisis creates extreme vulnerability to fraud and financial crime across our global financial systems.

The ExCo vs. The Status Quo brings together like-minded individuals and brands to illuminate the innovative actions companies are taking to make a bigger impact. This diverse community of industry leaders are building the conversation around what’s working, what’s not, and how to make things better – together – through a shared commitment towards a common goal.

Welcome to another ExCo vs. The Status Quo fireside chat where we bring together like-minded individuals and brands to illuminate the innovative actions companies are taking to make a bigger impact on the fight against fraud and financial crime. This diverse community of industry leaders are building the conversation around what’s working, what’s not, and how to make things better – together – through a shared commitment to a common goal . . . making the world a safer place to do business.

We were joined by Patricia Alleyn the Head of the Integrity Program for SNC-Lavalin, one of the world’s largest engineering, construction, and operations firms. With more than 45,000 employees and over $9 billion in annual revenue, the firm operates in over 30 countries delivering projects in the Infrastructure, Mining, Nuclear, Renewable Energy and Oil & Gas sectors.

In her role Patricia is responsible for the development and continuous improvement of a global ethics & compliance program designed to foster a culture of integrity and provide measurable compliance controls to monitor its effectiveness.

When I set out to get to know SNC a little better, what jumped out at me was how many common themes I found between our two brands, at the heart of what Exiger strives for and this campaign aims to highlight.  Here is an example:

Designing for the future is about more than predicting what it looks like. It’s about having the know-how and the expertise to turn predictions into projects that deliver results and meet ever-changing needs. That’s what we do every day: for our clients, for their customers and for the sustainable future of our business and the world we operate in.

And one more example . . .

Designing, developing and executing future-focused solutions has been at the heart of our business since day one. We turn complex projects from vision into reality for our clients, bringing together people, technology and data every step of the way to drive better outcomes across safety, sustainability and efficiency.

It’s clear that SNC takes very seriously its commitment to creating sustainable results, embracing change, making a difference and mastering complexity. 

Patricia has worked in compliance for 5 years and brings a unique perspective having studied organizational development while working in HR for more than 20 years.  In her time as Head of the Integrity Program, she’s led the function through some incredibly challenging times and, in getting to know her a little better, it sounds like she truly feels like the brand is better for it.

Why did SNC want to get involved with this campaign? What does ‘Making the world a safer place to do business mean to you?

Patricia Alleyn, Head of the Integrity Program, SNC-Lavalin: I think that the work we do as Compliance officers contributes positively to the P&L of the business, in other words, the financial health of the organization.

Patricia, you’ve been with SNC Lavalin for over 10 years and held a variety of Compliance roles – Senior Compliance Officer for Mining and Metallurgy, Head of Compliance Training and Communication and you’ve even worked in HR. How have you seen the role of ‘compliance’ change over the past 10-20 years?  How do see the COVID-19 pandemic further evolving it?

PA: Compliance now is similar to where the HSE function was 10 years ago. The evolution of our function went from simply applying laws and regulations to taking into consideration and applying Ethical principles. We went from enforcing rules to building integrity and ethical behavior into our organizational culture.

Covid-19 plus other recent world events are putting pressure on the business by creating a very uncertain economy. Ethical dilemmas are in many ways more present than ever, for example look at our supply chains. Productivity and logistics are being slowed down, resulting in shortages of material, and a change in the competitive landscape to favor those who can find needed materials or inventory. This is pushing businesses sometimes to make difficult decisions to make sure they are able to compete or even survive at all, which also implies that their tolerance to risk has dramatically increased.

We went from enforcing rules to building integrity and ethical behavior into our organizational culture.

How has technology impacted your company’s ability to keep up with regulatory change and your expanding global third-party network?

PA: Technology has helped us to provide the right advice to the business and sometimes recommend against (or withhold approval for) pursuing certain business relationships. Technology has also improved our data analytics and is helping us to recognize compliance risks and trends which enable us to act more quickly.

Our biggest concern is the ongoing monitoring, which we have a hard time including in our processes. This is an element that is now looked at more closely by regulators. Part of our focus in 2021 will be to implement technological solutions to improve this aspect.

Increasingly, the market is receiving encouragement from regulators to innovate in their compliance programs, policies and procedures . . .what does that mean to compliance officers?

PA: It is pushing compliance officers to go beyond the checklist and put in place a program that fits the organizational, industry and location/geographical risks and makes staying compliant easier.

For example, we have created a ChatBot to answer the most common questions we have from our employees. We have also created a “mobile app” which includes our Code of Conduct, our Compliance Procedure, access to our Reporting Line, access to the Gift & Hospitality Scorecard, access to micro learnings, etc.

The next phase now is to make sure that we have the mobile version of our chatbot. We feel that sometimes people don’t want to call their integrity officer, they don’t want to bother anyone, so they choose to go on the chatbot and ask simple questions and they’ll get an answer. It’s as simple as that. We’ve actually tried to add some artificial intelligence into it because we wanted to make sure that if people are writing their questions differently than we anticipated, the machine will still understand exactly what the person wanted to say. Sometimes it’s giving them options – the more people choose options towards a question, the more the machine is learning that that’s the answer that the person would want. It’s fantastic in a lot of ways – we also use it internally.

How do you think our current economic environment could accelerate the need to innovate to do more with less?

PA: I think that more and more businesses see automation and artificial intelligence as an investment to reduce not only their cost in the medium/long term but also to reduce risks that can lead to financial or other impacts.

How has your partnership with Exiger helped you accomplish your compliance priorities?

PA: We are using DDIQ to do our Enhanced Due Diligence. It permits us to have more in depth details on third parties for our Due Diligence process. It has influenced important business decisions related to our Business partners.

When SNC acquired Atkins in 2017, I had only 12 months to make sure that Atkins was fully integrated into our program. That’s not a long time for the number of employees in many different countries and cultures. The first thing my entire team and I did was an in-depth analysis of what we had, what they had, and what the best practice was between the two, and then we tried to adopt it.

One of the good things that Atkins was doing, although they were not doing due diligence on every single one of their third parties like we did, was that they were doing more thorough due diligence on some of them, some of their business partners, under certain conditions. When we look at the reports that they were doing, we were really amazed by the length and depth of the assessment that they were doing on some of their third parties. They were mostly using their team in India to be able to do that, which they called the compliance assessment team.

In the first couple of months after the acquisition, I went to India. I looked at everything that they were doing and came to think very, very quickly that this was actually an awesome way of approaching the third parties that maybe are more at risk. We’ve actually integrated that portion of the more thorough due diligence done by the Compliance Assessment Team. We’ve asked the CAT now to be able to do that, on the list of some of our business partners or sponsors for which we think maybe we need a bit more thorough due diligence than just the checks that we’re doing through another system that we have.

Most of the thorough due diligence that they were doing was using DDIQ. There was a lot of work behind it because there’s a lot of findings through DDIQ. They had to filter through those, but it actually gave us really good data on these business partners, and to decide sometimes that we didn’t want to do business with them or that it was okay, but we may want to add some measures to mitigate risk. That’s what we’ve been doing with your tools and that’s how it helps us to really make the right decision. We’ve really, by the way, made important choices on some of our existing partners, just based on the findings that we had.

Given our role in your process, what happens when we make a mistake . .  . what’s at stake?

PA: Sanctions, fines, charges, reputational damage, etc…

It is important to understand that business decisions made by some previous executives of SNC-Lavalin created a major scandal that put the business in turmoil for years. We were sanctioned by the World Bank, we were criminally charged (now dropped), we had to pay fines, and sustained reputational damage that lasted for years. This translated into the loss of clients and projects, business partners, share value, and employees, as well as creating major legal expenses and other issues. That is because the due diligence was not done properly before the scandal. The due diligence was not necessarily done on everything business partner.

The only way for us to do due diligence properly is not only to base our actions  on professional instinct, but to also have the facts and the data to support good decision making. It’s being able to say to the Board of Directors, “This is what’s going on right now. These are all the facts that we’ve uncovered. This is how we could make these links and this needs to stop now or else we’re just going to go back into the same story that happened in the past.” The solution that you guys provide helps us to make sure that we’re not dealing with third parties that could actually be very dangerous for us. The solutions that you provide to your clients enable them to make the right business decisions based on accurate information. This is the biggest benefit you bring to us.

The only way for us to do due diligence properly is not only to base our actions on professional instinct, but to also have facts and the data to support good decision making.

My last point is that people pay the most on what happened in these years – shareholders pay the price, but so do employees. I mean, we had to let go thousands of people because of those problems. The share price dropped and that hurt investors, but most of the employees at SNC have a retirement plan that’s partly dependent on that as well. Suddenly people who were planning on retiring didn’t have enough. They lost most of their savings as a consequence of all this. The human impact is huge. It not only costs millions and millions of dollars, it also costs people their jobs and their futures. People sometimes forget this when they look at a company that’s had issues like we have.  That’s why what you do is so important.

When you think about everything your company has been through, what are the biggest challenges facing SNC related to financial crime and corruption today?

PA: The creativity and sophistication of the processes and strategies used by the perpetrators. They reinvent themselves faster than regulations and traditional tools can adapt. That is why we need to invest in tools that include automation and artificial intelligence, so they can learn and improve themselves constantly with experience and findings. I think that this is what we need to go towards, although that is probably a huge investment in technology.

We need to invest in tools that include automation and artificial intelligence, so they can learn and improve themselves constantly with experience and findings.

Can you think of a company that you really respect who is also innovating to make the world a safer place to do business other than SNC?

PA: There are many examples but a few come to mind that I’d like to share:

  1. Almost everyone is doing something great. I read two articles yesterday on what Novartis is doing now on their new code of conduct – that they actually base the review of their code on principles of behavioral science. So, they actually surveyed thousands of their employees on their responses to ethical dilemmas with questions on their values or what they considered as ethical decisions and so on. From this, they came up with that fantastic code of conduct. It was actually really interesting.
  2. Impact through collective actions and focus on communities: Siemens through their rigorous processes plus their global “Siemens Integrity Initiative” with more than 100 million US-Dollars which supports organizations that fight corruption and fraud through Collective Action, education and training.
  3. Impact with technology: Accenture Code of Business Ethics – Cobe Chatbot

I think that we need people and companies that have a strong program to really talk about it and to influence the markets in which they operate to make sure that we’ll all become stronger. And as you said, we will make business safer if people take a stance and showcase what they’re doing so other people learn and follow suit.

Everyone wants to hear about the transformations other companies have gone through. How can we learn from them and, ultimately, make a bigger impact on the fight against financial crime. In that vein – if there is one legacy you can leave behind in your career around making the world a safer place to do business, what is it?

PA: Influence people to apply the principles of Critical Thinking. Meaning not to take any one piece of information as being an absolute truth, by being skeptical, doing research and basing decisions on facts and multiple lines of evidence. Question the status quo by seeking improvement, collaboration and innovation.

Question the status quo by seeking improvement, collaboration and innovation.

When you have a fact in front of you, be skeptical about it,  do your research. Look for other facts. Look to see if that information is also available somewhere else, make sure that you build your own opinion. And then with that in hand, decide on your own what exactly needs to be done or what exactly happened.

If we want to make sure that the business is working in a safer place, I think that we cannot just accept any information we receive as being factual.The people that are acting in a corrupt way or perpetrating fraud are in many cases able to get away with it because they assume people will believe any information given to them.. They think that you will blindly accept an invoice or an email just because it says someone approved it.

Make sure that when you’re making a decision you’re making it based on facts — that’s actually what Exiger delivers –  a bunch of facts.

Rapid Fire Round with Patricia

  • Favorite Place to Travel: The world. I miss traveling.
  • Favorite Food: Is wine food?
  • Favorite Show to Binge: The Crown
  • Favorite Book: Too many. Just finished the Culture Map from Erin Meyer. Must read for everyone that works with global teams.
  • Favorite Band/Singer: I love all sorts of music. I love classical music, jazz. I love hard rock. If I need to choose just one though like on a deserted island, I would probably bring U2 with me.

The risk landscape is constantly changing. Hear about the latest with Exiger.