Corporate Culture Key Element for Effective Compliance

Jane Fogarty

A Conversation with Jane Fogarty, SYNNEX

As vice president and senior counsel with SYNNEX Corporation, Jane Fogarty has dealt with a global matrix of compliance issues related to information technology. She shares her insights on the best ways to effectively manage a complex and far-reaching network.

What are the top legal issues you have to deal with in today’s environment?

For a large global company, ensuring compliance in all the jurisdictions in which the company is active is paramount. Knowing who is representing you in these jurisdictions is really important. Liability under U.S. laws like the FCPA doesn’t disappear when you have an independent contractor doing your bidding. U.S. headquartered companies also need to comply with U.S. export regulations around the globe. Trade sanctions in this current environment are also challenging. Deciding where to move the business internationally now has to be scrutinized through a lens that includes tariffs and other sanctions that could make market expansion decisions not profitable.

What strategies have you found most effective to stay ahead of the curve in managing compliance?

Getting out and visiting offices. Staying in your corporate head office is ineffective in ensuring that the cultural message is getting out. When a company grows by acquisition, it is even more imperative. Making sure that there is one culture in a large, international organization is hard work but essential in ensuring that compliance objectives are met. Any internal reports of breaches of your code of conduct must be dealt with efficiently so that employees know that if they do report something, it is handled expeditiously. Do that a few times and your employees get the message that management has got their back and any new issues will be brought to management’s attention promptly.

What cultural factors do you strive for in putting together teams to address the most complex problems your company faces?

I am a big believer in having diverse teams. It is through diversity that you bring different viewpoints to a problem and the risk of overlooking a crucial issue is less. The resulting solution is of great value. I look for people who can work in teams and also be comfortable working independently. For any team, communication is key. This doesn’t mean everyone in the same location. Today, technology to help you to keep in touch is readily available and makes creating and working with teams so much easier.

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