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Compliance as a Change Agent Through Industry and Beyond

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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.

Alma Karibo is the Compliance and Data Protection Officer at 54gene.  54gene is pioneering the inclusion of the African genome in research which, until now, has been largely ignored.  They are building the world’s richest and most diverse genomics datasets to generate insights that uncover the true drivers of disease.

Why did 54gene want to get involved with this campaign and what does ‘making the world a safer place to do business’ mean to you?

Alma Karibo, Compliance and Data Protection Officer at 54gene: We are a company in the life sciences sector providing precision medicine and our main goal is to improve the quality of health to people especially in the African region. That means we are a solution provider. One of our unspoken objectives is to make life better. Making the world a safer place means improving life.

I like to say that you cannot provide solutions to one area and default in another. You can’t say you’re a solution provider and at the same time be complacent or contribute to another problem. If you want to say you are truly providing a solution to any problem at all, it must also show up in your business conduct. The ethics you abide by as a company will prove whether or not you’re indeed set up to do what you say you want to do.

For us in Nigeria, being that solution provider, it’s really important to show that we’re not just providing solutions as it relates to healthcare. We are setting an example in the field that we find ourselves and in the jurisdiction we’re operating out of.

You cannot provide solutions to one area and default in another. You can’t say you’re a solution provider and at the same time be complacent or contribute to another problem. If you want to say you are truly providing a solution to any problem at all, it must also show up in your business conduct.

So while we’re doing business, one must show that it is possible to do business ethically in spite of the risks that are commonplace in our industry and our jurisdiction. That’s why it’s really important for us to focus on how we conduct ourselves internally, externally and as we relate to our third parties or business affiliates, not just in our business but also in our approach. Being a compliance program that is ethically upright trickles down to every single employee within the business.

Being a compliance program that is ethically upright trickles down to every single employee within the business.

You are building a compliance function from scratch at one of the most exciting companies in Nigeria and globally right now. What has that experience been like for you?

AK: Very exciting. Maybe because I’m very passionate about the subject matter, but also because of my background. I’m a lawyer, and I have a legal background having worked at a law firm within the oil and gas space. And if you’re familiar with compliance risks, you will understand what that means, and in Nigeria especially.

I also worked in a capacity where I wasn’t able to influence as much. I would advise, but you couldn’t really influence business decisions. Since I didn’t previously work as a compliance officer, I took note of how things were being done, especially from the government agency side of things. It would really prick at me. I would have sleepless nights just thinking, “Oh God, if only I had a magic wand to wave and make everything better.”

So, joining 54gene was amazing because at first I did not know what to expect. Having a legal background and coming into compliance, I thought to myself, “I hope I’m not going to be too legal for the compliance sector.” The training to prepare myself was however really exciting because I saw that in my role I would be able to make a positive impact and cause things to change. So taking up this position has really just been a journey of excitement. Getting to meet the wonderful team at Exiger has also really opened me up to many possibilities and opportunities.

Given that 54gene is relatively young and located in Nigeria, can you talk about the assumptions you’ve had to address given the presumption of risk associated with doing business in the life sciences sector and Nigeria?

AK: The life sciences sector is considered a high-risk area. I look at it from the perspective where it has to do with humans’ life and a lot could go wrong if people are not attentive. Within the jurisdictions where we operate, there are assumptions that everybody, in general, does business in a certain way.

There is a common perception of corruption across the board, regardless of the industry. Whether it’s the oil and gas sector, the life sciences, pharmaceutical companies. I’ve been told of raid exercises that expose the corrupt practices of the production of counterfeit that are put out in the markets and what goes on commonly.

And that’s the perception even when you deal with counterparts in this area. They’ll ask “Why are you asking us to provide a code of conduct? Why are you asking us to provide an ABC policy?” And then you give them due diligence and KYC forms to fill out and they’ll just write “no”. They can’t understand why you’re asking for it at all. But we insist and that sends a note on our standard.

Those are like the general assumptions. This is why I say I’m really happy and excited working as a compliance officer within 54gene because everyone, especially in management, understands the value of upholding our standards.

Somehow in these regions, young people are standing up for what’s right and standing up to challenge the status quo. We’ve had constant protests going on and all of that is an uprising against the norm or current status quo. Maybe because we have a good variety of young people on our management team, it’s quite easy as we have the same mindset of doing things and moving away from what is normal, what is accepted. Being that difference is really important for us.

Young people are standing up for what’s right and standing up to challenge the status quo.

We’ve really done a good job. I don’t know if that has anything to do with the recruitment process, but everyone at management level has a different mindset of what you find common in Nigeria. That is what’s key for us, beyond the business of providing, or improving the quality of health care to Africans. Our goal is to carve out a niche and associate our name with making a difference within our sector and within our jurisdiction in Nigeria.

I’ll give you a testimonial from 54gene. We started doing COVID tests when the pandemic was really intense and there was a lockdown. Around that period, we had just completed a compliance training for about 50 team members and one area of focus was the policy around not accepting bribes and generally holding up standards within the organization. Shortly thereafter, one of the team members who attended the training went to a high net worth individuals’ house to conduct a COVID test. After the individual’s interaction with our customer support, he voluntarily offered her money and she declined despite his insistence.

If someone does something for you or gives you a service that you consider top notch, you want to appreciate it because it’s not commonplace in Nigeria. So he just wanted to show appreciation but she remembered her training and declined. That individual came back with feedback on how impressed he was by the fact that she rejected the offer. He was very pleased and stated he was really looking forward to seeing the kind of impact that 54gene is going to have, not just in the health space, but affecting regulatory compliance. His excitement struck a nerve, it really did.

I know your founder and CEO, Abasi Ene-Obong has reached a high and well-deserved status in Africa and globally across the life sciences industry at this stage. What people may not know is what a formidable champion for ethics he is. How has his support shaped your program?

AK: His support helps me to take on the role with so much boldness. In one of my first interactions he had mentioned how important compliance is to our growth. Even then, when I took the requisite training to prepare me for the role, the importance and value of the tone at the top was emphasized a lot. I used to wonder, why did they make so much noise about that but I realized it’s because it’s difficult to get management’s buy-in to compliance. There’s a lot of pushback; perhaps because it could affect business or revenue generation and so on and so forth.

For me, I am yet to have that sort of experience. I don’t think it is something I would ever need to look forward to because Abasi Ene-Bong has been extremely supportive. Again, maybe because we’re a younger generation within the company and we understand or maybe our collective experiences from the impact of corruption and compliance violations has something to do with it but it is really inspiring. Abasi is my foremost compliance champion. When we have meetings around getting a regulatory visit or getting support from the government, he’s always echoing, “be sure to carry Alma along. And Alma, please provide guidelines as to how we should do this or how we should engage the agencies and so on and so forth.”

That level of support and inclusion has made my job easy so that when I go to heads of departments and I’m having conversations, they understand that this is the expectation from the top of our company. And in my experience, they will not behave short of his expectations or interfere. We don’t see the job as isolated. We see it as part of making the business or making the environment better and more ethical.

We don’t see the job as isolated. We see it as part of making the business or making the environment better and more ethical.

Increasingly, the market is receiving encouragement from regulators to innovate in their compliance programs, policies, and procedures. Can you talk a little bit about what that means to 54gene in this moment?

AK: I like to make the things that I say a little more practical and personalize them as much as I can.  I would like to speak to an incident that happened and what we’ve done using tech to respond to the associated compliance risk beyond just policies and procedures. 

Early in the COVID-19 pandemic, when we got involved with testing, there were very few others providing tests in our region. At the time, it was only the government and hospitals doing it. We were really the first private company to begin testing and then a few other laboratories came on board. In Africa, before you travel, you have to show a negative COVID-19 test result. We discovered that people were forging our test result templates after carrying out investigations because we’d gotten feedback from government agencies that they believed some results were being presented on forged documents. This was a huge violation for us as a company but also for the integrity of our process. Anything associated with our name, likeness or trademark is linked to 54gene and affects the perception of the brand, authenticity and trust we’ve worked hard to build. We knew we had to take action and so we used technology to build an authentication portal where the government or immigration offices, embassies and even airline operators can go into the portal using an access code to verify any result that is presented and an agent can tell immediately if the result has been forged or duplicated.

Perhaps the best part of the solution we created is that now other labs are putting their results into the portal so the technology has been adopted widely to bolster the integrity of the entire industry and build confidence in our community around the testing process and the trust people need to feel safe when they travel. I think that is one of the most innovative ways we’ve used technology to quickly curb a compliance risk.

We’ve talked a lot about innovation, the work 54gene is doing, and the compliance program that you’ve built. Can you share an example of another company that you respect, who is innovating to make the world a safer place to do business?

AK: If I’m being honest, the only company that stood out for me is Exiger. I don’t think I can tell you what you’re doing and how you’ve impacted me in just recognizing that the fight against all the pain is not isolated. There’s a lot of support from companies who act as consultants. I say that maybe because of my previous employment, where I’ve seen how some consultants will work with the company to sort of cover things but not be able to provide transparency or real guidance that sets the company apart. That’s not been the case with Exiger.

There’s a lot of support from companies who act as consultants. I say that maybe because of my previous employment, where I’ve seen how some consultants will work with the company to sort of cover things but not be able to provide transparency or real guidance that sets the company apart. That’s not been the case with Exiger.

Even with this campaign, it is clear that the effort is being made. You are recognizing various individuals in various sectors, collating all of that talent and being able to promote it or show it any way so that if somebody, all the way in China or Kenya sees, “Oh, there’s a company in Nigeria, who’s doing XYZ different fromwhat is known, they’re able to say that we set ourselves apart. That in itself communicates that we are making the world a safer place.

If there’s one legacy you want to leave behind in your career around making the world a safer place to do business, what is it?

AK: I guess it would be starting from an individual level to demonstrate that if one person recognizes they can be the difference, then they can communicate that to the next person, right? if I am able to, in my communications and interactions with my friends and acquaintances who may not know anything about compliance and who are not compliance professionals, I’m able to say, Oh no, this is not right. I can lead by example and say, “This is what I stand for”. Maybe they will remember that and find inspiration to do things differently when they have an opportunity to make a different decision . . . to make a better decision . . . to make the right decision. 

Demonstrating to others that, even in their personal lives, they can be the difference in spite of the norms or the assumptions that may exist. That would be a legacy for me.

Demonstrating to others that, even in their personal lives, they can be the difference in spite of the norms or the assumptions that may exist. That would be a legacy for me.

Thank you for spending International Women’s Day with us. You are ‘choosing to challenge’ and encouraging others through your leadership. Everyone has the ability to effect change and the littlest things can make the biggest differences. The incredible power we all have to move the needle is remarkable even more so when we put our differences aside and work together.

Rapid Fire Round with Alma

  • Favorite Places to Travel: Los Cabos, Mexico
  • Favorite Food: I’m a foodie, so I can’t decide.  Internationally, I would say pasta, but locally I would say jollof rice.
  • Favorite Show to Binge: How to Get Away With Murder or Girlfriends
  • Favorite Book: The Bible
  • Favorite Band/Singer: my favorite band right now is Maverick City Music. As for my favorite singer, I’m not sure. Maybe Whitney Houston or Alicia keys. I’m undecided!

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