Over this podcast series, I visit with Vin DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. We consider the global view of ethics, compliance and corporate culture of non-US companies, outside the US; in both their home countries and in other countries where they do business. AMI does independent integrity monitoring in multiple countries outside the US and for many non-US organizations. This work has given them a unique vantage point to observe developments. In this Part III, I discuss trends in ethics and compliance programs in Spain with DiCianni.

DiCianni noted that corruption has been a long-standing problem for the country. However the government has moved to address this problem. This has led to a great interest in compliance programs, leading to more robust ethics and compliance in organizations. This is in the face of no real government enforcement efforts. It seems that organizations are looking to implement a compliance program literally for themselves. Further, they are doing so to help themselves move to a proactive level of compliance rather than simply reactive.Two areas that interest me about working with and traveling to countries outside the US are the local compliance practitioners. The first is that compliance professionals outside the US are very enthusiastic about the compliance practice and the compliance profession. Moreover, they really believe in compliance and ethics and that they can make a difference inside of a corporation to help change an entire country’s culture. The second observation is that I see a lot of people directly out of college in their mid-twenties with this enthusiasm for compliance going into the compliance field.

DiCianni certainly agreed with the first observation. He said, “compliance officers, once they take on that role and they understand the importance of it and they understand how compliance is being used by other companies. I saw that firsthand in almost everyone that was in the Madrid and Bilboa AMI roundtables I led. It is very palpable to see how much they really like the compliance function. People never want to go back to their old roles. They really liked the compliance role and helping the company.” He disagreed with my observation on the youth. He found that most of the compliance professionals he met, came from other corporate disciplines such as the legal department. This was certainly the path I took and the path for many in the compliance profession here in the US.

From the corporate perspective, one of the things DiCianni has observed is multi-national companies bringing compliance into Spanish corporate culture. From there they are driving compliance through their supply chain and other third-party relationships. DiCianni observed another interesting driver for compliance in Spain is that both law and accounting firms are pushing their clients to invest in compliance programs.

DiCianni concluded by noting that while compliance is a concept that many practitioners and corporations are comfortable with, the values-based ethics portion that has taken hold in other countries is not as prevalent in Spain. Things like a whistleblower hotline, how it is supposed to work and how it is supposed to be effective is really not considered. In their area of training, there is a plethora of computer-based training but not the type of training which makes it more topical for people. He observed that when “you talk to people about ethics, it’s really a new concept for them. They understand compliance and complying with the rules, but ethics is something different.” Even most compliance professionals have not received any instruction  about ethics. He concluded that in many ways “it’s sort of a new concept for them.”

Tomorrow we consider developments in independent integrity monitoring through international enforcement.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.

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