Compliance & Ethics

March 2015 Professional

a publication of the society of corporate compliance and ethics www.corporatecompliance.org

How Ernst & Young is training its Brazilian team

by Adam Turteltaub Vice President of Membership Development at SCCE See page 14

17 27 37 41  Eight steps in The dominant CEO: Myths of Compliance dilemma: launching an information Great for business and anti-corruption It takes disruption to governance program terrible for compliance? compliance beat corruption Mark Diamond Ted Banks Alison Taylor Geert Aalbers

This article, published in Compliance & Ethics Professional, appears here with permission from the Society of Corporate Compliance & Ethics. Call SCCE at +1 952 933 4977 or 888 277 4977 with reprint requests. FEATURE by Ted Banks The dominant CEO: Great for business and terrible for compliance?

»»The personality of the CEO has a significant impact on compliance. »»A red flag is the CEO who follows only his/her own rules, as opposed to company polices.“La compagnie, c’est moi.” »»Another red flag is the CEO who doesn’t believe in any sort of corporate governance or compliance structure. Trust can be overdone. »»Chief compliance officers must understand the CEO’s personality, as well as the corporate culture, in order to design an effective compliance program. »»The business may be successful in the absence of an effective compliance program, but eventually, it will suffer.

s there a correlation between ethics and to reward companies for their ethics, only business success? The Compliance and for their profit and loss (P&L) statements or IEthics community, of course, loudly balance sheets. CEOs see this, and direct their proclaims this fact. There may be such a attention accordingly. This focus is reinforced correlation for several reasons. Your company by the media attention paid to the “strong” makes more money if you aren’t paying huge CEO who imposes his (or, occasionally, her) fines and legal fees. Management vision on the company. That vision rarely, if can pay more attention to the ever, includes an ethical component. Yet the business if they aren’t preoccupied strong CEO, through some combination of with litigation—or in jail. Business business acumen, luck, and a media-friendly partners, including consumers, personality, becomes a darling of the business may well shun a company that is press, investors, and b-school case studies. constantly in legal trouble ranging up Banks to formal debarment for government Is Warren Buffett the right model

contractors convicted of (or, in for Compliance? March 2015

some circumstances, merely suspected of) It is interesting to compare two examples of wrongdoing. “rock-star” CEOs: Warren Buffett and Steve But even if there is a correlation, the Jobs. Buffett’s firm, Berkshire Hathaway, has sad fact is that ethical business operations been very successful, and he has become may not be a necessary precondition for a cult figure, although with a decidedly business success. Wall Street may punish modest life style. He has also made a point of companies after they have been caught in stressing the importance of ethical values in an ethical violation, but it does not seem his activities. When Buffett testified before the Compliance & Ethics Professional

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House Committee on Energy & Commerce in powerful dynamic for people to do the right 1991 about the problems at Salomon Brothers, thing. But is this enough? he said, “Huge markets attract people who Munger and Buffett do understand that measure themselves by money… sooner or with 300,000 employees, there are going to be later they’re going to end up in trouble… problems. The no-staff-at-headquarters system Lose money for the firm, and I will be that Berkshire has established has sometimes understanding. Lose resulted in problems, a shred of reputation such as a recent fine for the firm, and I The no-staff-at- from the FTC for will be ruthless.” headquarters system that a repeat violation Buffett had earlier of the Hart-Scott- directed the company Berkshire has established Rodino reporting to cooperate with has sometimes resulted requirements. The the government company agreed investigation, in problems, such as a to pay $896,000 to including waiving recent fine from the FTC settle the case, after the attorney-client for a repeat violation of having violated the privilege. He also same rules in 2013, directed that the the Hart-Scott-Rodino and giving the FTC public relations reporting requirements. assurances that it consultants be would implement a discharged. “It isn’t compliance program.4 that we’re misunderstood…. We don’t have a This “technical” violation of the rules perhaps public-relations problem. We have a problem could have been avoided had there been with what we did.”1 sufficient staff to ensure that commitments But Buffett, of course, is not perfect. made to establish a compliance program were When a close associate of Buffet’s, David actually followed. Sokol, apparently engaged in insider trading, Buffett’s personal honesty seems to be Buffett initially defended his colleague, above reproach, but just setting an example who was rumored to be Buffett’s successor. is not enough to ensure a good compliance Later, as more facts were revealed, Buffett program. It may be necessary, but it is not stated that Sokol’s trades violated company sufficient. The same principle holds true for policy, and his actions were “inexplicable corporate governance. While Buffett’s stated and inexcusable.”2 aversion to investing in businesses he doesn’t Buffett and Charlie Munger, vice chairman understand and his modest annual salary

March 2015 of Berkshire Hathaway, take an extreme are held up as examples of good governance,

approach to compliance—they “overtrust.”3 sometimes there is a lack of fundamental The company has a tiny headquarters due diligence in business decisions, due to staff, without a general counsel or Human his reliance on gut instinct that may result Resources department. Their stated policy is to in questionable business decisions.5 This hire people they trust, and then get out of their kind of decision-making obviously can lead way. By establishing principles that everyone to bad investment decisions. It can also lead is expected to follow, rather than rules that to problems in overall management of the people might try to evade, there is a relatively people in a company. When decisions are Compliance & Ethics Professional

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made based on the instincts of a leader rather market rewards Berkshire Hathaway for than transparent principles (such as corporate anything other than business performance. policies), there is risk that the ability of The Buffett/Munger formula requires the employees to conduct business without fear “right basic controls.” Even with the tone of of reprisal can be compromised. For example, ethical behavior firmly in place, removing right after Benjamin Moore & Co. had its first the infrastructure necessary to accomplish a profitable quarter in five years, the CEO was culture of compliance can make it impossible fired abruptly for an “ineffective corporate to fully comply with all of the rules our legal strategy.” A lavish Bermuda cruise for the system imposes. It certainly would not look subsidiary’s top management to celebrate like an “effective” compliance program under the company’s success may have contributed the Federal Sentencing Guidelines. to the termination, but, if true, that The Steve Jobs runs counter to the In spite of legal problems CEO model stated philosophy of over the years, evidence In contrast, perhaps, allowing business is the example of managers to manage appears that the Jobs Steve Jobs and Apple. as they see fit. This approach to ignoring Jobs resurrected a may be consistent struggling Apple with Buffett’s inconvenient legalities may after he returned insistence on a have continued at Apple to the company he modest lifestyle, but after Jobs’ death. helped found. A were employees series of innovative aware of actual products followed, corporate limits? Were there any rules in reflecting his passion for elegant design and place? The successor to the discharged an understanding of how humans function CEO was also terminated in response to (or could function). He intensely cared about allegations that he has sexually harassed his products, but in his quest to achieve the female employees. vision of what he thought was right, nothing If those instincts lead to hiring friends else seemed to matter. According to his because you trust them, that may work—but biographer Walter Isaacson,6 Jobs’ relentless it may also lead to the hiring of people who, pursuit of his vision of what should be in his while trustworthy, lack the business skills the products, and his absolute conviction that he job requires. Many people who are found to was right about any subject, led him to great have defrauded businesses were perceived product success but also product failures,

as loyal, hardworking, and, of course, honest ethical lapses, and, ultimately, his early death March 2015 employees. Relying on setting an ethical as Jobs ignored medical advice that conflicted example, and trusting your instinct on who to with his own ideas. In spite of legal problems hire, are just not enough to ensure compliance. over the years, evidence appears that the Jobs Notwithstanding the occasional misstep, approach to ignoring inconvenient legalities it is clear that Buffett sets a tone of ethical may have continued at Apple after Jobs’ death. behavior that resonates throughout the Nevertheless, the business continues to be companies that make up Berkshire Hathaway. hugely profitable and the company’s stock But the question remains as to whether the continues to trade at stratospheric levels. Compliance & Ethics Professional

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However, it is fair to ask whether the sale model used by Amazon (i.e., the book Apple’s legal problems over the years was sold to Amazon, and Amazon re-sold it represented “routine” legal problems that at whatever price it wished to charge) to an might encountered by any large company, agency model (i.e., Apple would receive a 30% or were a reflection of the values of the CEO. commission on the sale of books at whatever Apple was one of several hi-tech companies price the publisher wished to charge). The that participated in the Silicon Valley “anti- publishers thought that Amazon’s prices poaching” conspiracy where each agreed were too low and adversely impacted the not to hire the employees of the other. Steve sale of hardbound books. If they responded Jobs appeared to be the central figure in this by raising their prices to Amazon, Amazon arrangement. All of this was clearly illegal often failed to respond by raising its prices under the antitrust laws. The insistence of Jobs and simply took a loss on the sale of the in getting his own e-book. Jobs (and, way was reflected in presumably, his the way he brow-beat Additionally, lawyers) understood other Silicon Valley although appeals are this, and offered the executives. For publishers a way to example, according ongoing, Apple has make more money to an email produced been found guilty of on the sale of e-books in the litigation, Jobs by switching to the called Sergei Brin facilitating a price-fixing agency model. But the at Google and told conspiracy for the sale system would only him that if he hired of e-books. work if all of the major a “single one” of the publishers were on people from Apple, board, and emails from “that means war.” Such was his power that no Jobs showed that he personally pushed other company, including giants such as Intel for the agreement. Although others were and Google, wanted to anger Jobs. involved, including company lawyers, this Additionally, although appeals are was clearly an idea that was fixed in Jobs’ ongoing, Apple has been found guilty of head. According to the government case, this facilitating a price-fixing conspiracy for the was an illegal conspiracy orchestrated by sale of e-books. The agreements between Apple, which violated the Sherman Act. The Apple and five large publishers resulted publishers all settled the charges that had in a significant increase in the prices that been brought against them. Apple refused to consumers paid. The prosecution by the settle, went to trial, and lost. The judge agreed

March 2015 Department of Justice for violation of the with the government that Apple solicited

antitrust laws was followed by civil actions and facilitated an illegal agreement that by a number of parties who alleged that they restrained competition among competitors were injured by the conspiracy and resulting (the publishers). price increase. Jobs also had a well-documented obsession In the e-books case, the evidence showed with music. This is reflected in his push to that Jobs pushed to have an arrangement with develop the iPod and control the music that publishers in place at the time the iPad was was played on it. In yet another major lawsuit, released. The proposed agreement would shift Apple was accused of violating the antitrust Compliance & Ethics Professional

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laws by forcing iPod users to purchase higher- difference. In a New York Times article,7 James priced music, since technological tools were B. Stewart asked the interesting question, “If used to prevent other music files from being Steve Jobs were alive today, would he be in played on the Apple devices. Jobs and Apple jail?” As noted above, Jobs was at the center defended the practice as a way to prevent of several legal controversies over the past liability for copyright violations, but it can few years, involving antitrust (e.g., e-book also be seen as a relentless drive to accomplish price fixing, anti–job-poaching conspiracy) a business goal and securities without concern for laws (e.g., options legal consequences In the Isaccson backdating involving (or smaller biography, Jobs’ use of both Apple and competitors). Pixar, where he was It is somewhat the “reality distortion CEO). The defense of difficult to speculate field” was common. For Jobs in the options as to what goes backdating case on behind closed some, this was just another basically was that doors in a business, way of saying that Jobs he didn’t know but we get hints of tended to lie. what he was doing, internal conduct yet the evidence and misconduct at showed that minutes Apple from the Isaacson biography, and from were fabricated for a board meeting that the evidence presented at the price-fixing never occurred. trial. These bits of evidence paint a picture of In the Isaacson biography, Jobs’ use of the the type of culture that Jobs created at Apple. “reality distortion field” was common. For Jobs had a reputation for being totally focused some, this was just another way of saying on his vision of what an Apple product that Jobs tended to lie. But it also represented should be. Other considerations—such as a desire to bend reality to his vision and legal requirements—were just not part of his forceful personality to get other people his concerns. Although it may be unfair to to believe his vision, because Jobs had extrapolate from “little” things, like ignoring internalized it. This ability and willingness license plate requirements or parking to push people to do things they didn’t restrictions, these do paint a picture of a think were possible is one of the signs of the person who felt that normal rules—such as exceptional leader who can accomplish things laws—did not apply to him. that others could not. Jobs’ single-mindedness Our society seems to reward risk-takers— apparently was not constrained by other

when they are successful. It is one of the considerations, and this seems to be where the March 2015 mantras of innovation that you really need to compliance problems arose. As Isaacson said, fail before you understand how to succeed. Jobs believed that the rules that applied to But what seems to be forgotten is that there ordinary people didn’t apply to him. is an important difference between taking But it would be unfair to limit the a risk with a business idea versus taking a characterization of Jobs as someone who risk involving questionable ethics or legal simply ignored reality. Colleagues report that compliance. Here, it seems that Steve Jobs he had an amazing talent at solving problems, simply had no perception that there was a and his visionary side deserves the respect it Compliance & Ethics Professional

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has been given. While Jobs had a reputation of paranoia about employees who might not for treating employees harshly, there were have had his same single-mindedness. It was many instances where people stood up to reported that Apple had a group of employees Jobs when they believed they were right, and known as the “Worldwide Loyalty Team” (also he respected them for that. The problem was referred to as the “Apple Gestapo”) whose that it took a certain type of strength to resist job was to vigorously pursue any suspected Jobs’ personality, and the normal tendency leak of information. They would descend was for people to upon a department, allow themselves collect cell phones and to be pushed. The It was reported that require employees to stubbornness of Jobs unlock them so they didn’t just extend Apple had a group could be examined. to an insistence on of employees known They were told not following his design to communicate vision for products, as the “Worldwide with anyone while but included the Loyalty Team” (also a department exclusion of other referred to as the “Apple examination was considerations when occurring, and if they they may have had Gestapo”) whose job was didn’t like it, they nothing to do with to vigorously pursue could leave. It was product design.8 earlier reported that People were either any suspected leak the intense efforts unable or unwilling of information. to track down the to convince Jobs disappearance of an to do something i-Phone prototype at different when it came to options backdating, Foxconn, the Chinese company that makes employee poaching, or e-book pricing. With the device, resulted in the suicide of one of one exception, Jobs’ personality (and the tacit the employees who was interrogated. For economic threat that Apple could pose) forced Jobs, secrecy and loyalty were of paramount other Silicon Valley companies to go along concern, not because it was a matter of ethics, with his no-poaching conspiracy. The one but because it was a matter of business. exception? Sheryl Sandberg, who left Google Now that Steve Jobs is no longer to work as COO at Facebook. Facebook was with Apple, the question is whether the not named as a defendant in the employee company is committed to following all of poaching case. the Jobs management traits—including the

March 2015 Jobs’ business success seems to have minimization of the importance of compliance.

come without any particular recognition After Apple lost the e-books price-fixing that ethics were a necessary part of doing case brought by the Justice Department, the business. When he was asked about the ethical first report from the compliance monitor complications of genetic research and cloning painted a picture of a company determined in an interview, Jobs famously replied, “You not to admit that it had done anything wrong know - I’d rather just talk about music. These and determined to resist the attempts by big-picture questions are just - zzzzzz.”9 Part of the monitor to guide the implantation of Jobs’ fixation on his vision also included a bit a compliance program. Requests that are Compliance & Ethics Professional

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common in implementing a compliance The role of the CEO in compliance program, such as interviewing senior Moving beyond Apple and Berkshire managers and directors, were characterized Hathaway, it is clear that in many companies, by Apple as grossly intrusive.10 In this case, on Wall Street, and in business schools, there Apple was not just resisting the suggestions of is almost a “cult” approach to the CEO. The a monitor, but it was resisting the orders from media and investment community love to the sentencing judge regarding a compliance have a CEO they can talk about, and this program. There may have been legitimate may result in a situation where the company disagreement over whether the conduct of Jobs becomes so identified with the CEO that was actionable price-fixing, but once the case his/her word becomes law and nothing was lost, it seemed else matters. In the incredible to most business community, observers that the Moving beyond the appointment of company would the charismatic CEO continue to fight the Apple and Berkshire is often rewarded establishment of a Hathaway, it is clear that by a rise in the compliance program. in many companies, stock price, but it is Why would any often followed by a company take the on Wall Street, and breakdown in sound position of resisting in business schools, management and what appeared to governance principles be the objectively there is almost a “cult” that will eventually reasonable requests approach to the CEO. lead to disaster. of a court-appointed The role of the leader monitor? One in setting the ethical might speculate that it was the attempt by tone for a company is key. Sometimes the the company to assimilate the obstinate problems arise when a founder of a company, personality of Jobs, even after his death. But who had a key role in making the corporation things improved somewhat six months later, work, will stay too long as business and and the second report of the monitor indicated ethical problems mount. Dov Charney, the that Apple had implemented a revised founder and CEO of American Apparel, antitrust compliance program. was the subject of a number of allegations Compliance professionals understand regarding sexual harassment, and he was the importance of corporate culture and finally fired in 2014, after he apparently its effect on behavior. The psychology that released personal photos of a woman who

exists within a company can have a significant was suing him. There is also a recognition March 2015 impact on decisions that employees make. that in the scientific community, the traits Jobs commanded tremendous respect that describe a psychopathic personality within Apple, based on his intelligence and (e.g., calmness under stress, egocentricity) may his forceful personality. Jobs fostered a culture also be ones that enable a CEO to succeed. of moving forward without much thought It doesn’t seem that Jobs’ inattention to consequences, ethical or otherwise. This to ethical considerations fit into any of the resulted in a number of significant product standard models used to examine business innovations, and some legal stumbles. ethics. As Evgeny Morozov noted, in Jobs’ Compliance & Ethics Professional

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world, “there were only two kinds of people to into his thought process—and for that, the be reckoned with: producers and consumers. company, its employees, and its shareholders, Norms, laws, institutions, politics—none of that suffered. The “insanely great” company could larger context matters.”11 Jobs wasn’t necessarily have been even greater. immoral; his behavior suggested that he was amoral. Morals were not an issue. In fact, it may But is the Buffett model preferable? The well be that in order to achieve great results, a strong emphasis on ethics of Warren Buffett certain irrationality is required. The only way is clearly something to be admired, and to do the impossible is to press ahead and insist every CEO should demonstrate the same on doing it. commitment. But along with that commitment Many lessons about Jobs as manager can came a tendency to make business decisions be gleaned from reading about his life at based on instinct rather than analysis. The Apple. Stubbornness and commitment can idiosyncratic aversion to staff positions and be very powerful. Simplification of messages technology resulted in legal violations and and products is important. Demanding top business problems that could have been performance from employees is important to avoided had there been a more conventional establish excellence. But when other managers structure available to implement the Buffett start to emulate Jobs as manager, it is scary ethical vision as well as his business vision. to think that they will also assume that in The immense power vested in Buffett, together the drive to push out a product, nothing with the lack of structure, appears to have else matters. resulted in some confusion as to actual policy. In the Harvard Business Review discussion Structure alone is not an answer. of the best performing CEOs, Steve Jobs was Compliance can get buried in an elaborate ranked #1. The criteria for such judgments internal structure, with the result that nothing were financial: returns adjusted for countries gets done. This may be a reflection of an and industries, and market capitalization entrenched corporate culture. The CEO may changes. After going through the rankings, be unable to alter the culture, or be unaware the authors noted that there was zero of certain aspects of the culture that can correlation between the financial performance undermine the company. The result is like of the executives they ranked, and the social the “paper” compliance program: on paper, and environmental performance of their the corporate process looks thorough and companies.12 Unfortunately, the authors focused reasonable, yet nothing gets done. This can on indicators of corporate social responsibility be the result of an intentional strategy to (CSR), and not ethics or compliance. CSR is not avoid compliance, as at Enron, or it may be an an accurate proxy for compliance and ethics, unintentional result of a corporate bureaucracy.

March 2015 because the components differ widely from This has been widely discussed in the case

country to country. But the authors made no of the General Motors ignition switches. A mention of other ethical considerations or a report by an outside lawyer revealed that GM company’s history of litigation, which might be knew about a defect in ignition switches for an indicator worth considering. many years, but did nothing about it. The It wasn’t just that Steve Jobs was a difficult culture in the company was such that, while individual, or that he was inconsistent, or that there were many meetings and discussions he valued product design above all else. It was about the problem (i.e., there was a structure just that he would not allow ethics to enter to address the problem), nobody would take Compliance & Ethics Professional

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responsibility for fixing the switch, nor would ·· A risk assessment of a company should also they do anything that might publicly embarrass include a section on the CEO’s personality. the company or lead to liability. The general Legal violations at Apple and Berkshire counsel and CEO seemed to be unaware of the Hathaway (and other companies) occurred, situation. Needless to say, the lawsuits followed to a certain extent, because of the CEO’s soon thereafter. personality. In one, the CEO didn’t care; One way to think about this tension in the other, the CEO cared, but didn’t do between the value of the strong leader and much to implement his cares. The risk the need for objective compliance and ethics would be in proportion to the dominance of standards was suggested back in the 1982 book the CEO and the nature of the personality. by Thomas Peters and Robert Waterman, In ·· Perversely, the more successful a CEO is Search of Excellence. One of their attributes of perceived to be, the more difficult it may excellence was “loose-tight” management. be to implement an effective compliance There are certain areas where tight program. Chief compliance officers (CCOs) management is necessary (e.g., finance); other should take advantage of business success areas benefit from autonomy (e.g., shop-floor to bolster their program, and not allow activities). This principle applies to compliance management to adopt a complacent policy and business ethics, too. There need to be the that nothing more needs to be done. But cultural signals within the company, starting the CCO should recognize when the with the CEO, that might be thought of as dominance of a CEO threatens the ethics of “loose,” or subjective. But there also needs to the organization. ✵ be a structure to implement those things that make up the company’s values that can’t be The author wishes to thank Dagny Broome, Loyola left to examples or signals, and these would University Law School, JD Candidate (2016) for her be the tight or objective part of the compliance assistance in the preparation of this article. program. Both are necessary. 1. Alice Schroeder: The Snowball: Warren Buffett and the Business of Life. Bantam, 2008. 2. Ben Protess: “S.E.C. Ends Scrutiny of Former Top Aide to Conclusion Buffett.” NewYork Times Dealbook, January 3, 2013. Available at http://nyti.ms/15LXsgk Media stories about famous CEOs paint an 3. Andrew Ross Sorkin: “Berkshire’s Radical Strategy: Trust.” New York Times Dealbook, May 2, 2014. Available at incomplete picture, of course, but there are http://nyti.ms/1Lc55g9 4. United States v. Berkshire Hathaway Inc., No. 1:14-cv-01420 (D.D.C. some things that compliance officers can learn: Aug. 20, 2014)(stipulation). 5. Mel Duvall and Kim S. Nash: “Auditing an Oracle.” Baseline, ·· The personality of a CEO is a major factor August 2003, issue 21, p. 30. 6. Walter Isaacson: Steve Jobs. Simon & Schuster, 2011. in compliance. In addition to sending a 7. James B. Stewart: “Steve Jobs Defied Convention, and Perhaps the Law.” New York Times Business Day, May 2, 2014. Available at message that compliance and ethics are http://nyti.ms/1yW3KW4 8. (On this point I respectfully disagree with one Roy Snell, whose name important, the CEO must also support may be familiar to readers of this publication. Roy, in these pages, openly admired Jobs’ stubbornness as one of the keys to his business success, but

a structure for compliance where it did not discuss his apparent moral blindness.) Roy Snell: “Steve Jobs has March 2015 passed away.” Compliance & Ethics Professional, Letter from the CEO, is necessary. December 2011, p 18. 9. Evgeny Morozov: “Form and Fortune: Steve Job’s Pursuit of ·· If the CEO does not automatically send Perfection - and the Consequences.” The New Republic, March 15, 2012, quoting from an interview by Jeff Goodell that appeared in a message that ethics are important, the Rolling Stone on June 16, 1994. 10. Michael Bromwich: Report of the External Compliance Monitor, compliance officer will need to do it for United States v. Apple, Inc., No. 1:12-cv-2826 (S.D.N.Y April 14, 2014). 11. Ibid. ref #11. him/her—if possible. If not possible, or 12. M. Hansen, H. Ibarra, U. Peyer: “The 100 Best Performing CEOs in the World.” Harvard Business Review, January 2013. only partially possible, then there is a strong possibility that ethical problems may Ted Banks ([email protected]) is a Partner at Scharf Banks Marmor LLC in Chicago, and President, Compliance & Competition Consultants, LLC be on the horizon. in Highland Park, IL. Compliance & Ethics Professional

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