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Connected Compliance in a Global Market: Essential Elements of an Effective Compliance & Ethics Programme 2019


Speaker(s): Ali Sallaway, Alun Milford, Andrew Hayward, Anne Riley, Anton Alferov, Benjamin Slinn, Christine Braamskamp, Holly Insley, Johanna Walsh, Jonathan Chibafa, Judy Krieg, Katherine E. Palms, Lauren Taylor, Paul Brabant, Rebecca Walker, Stephanie Brown Cripps , Svatava Sprague, Tim Langton
Recorded on: Nov. 11, 2019
PLI Program #: 275621

 Svatava is Microsoft Regional Compliance Director in Western Europe. Her role is to provide legal oversight over internal investigations in the region and to co-ordinate with local and headquarters stakeholders on a number of aspects of Microsoft's global compliance program, including anti-bribery & corruption and third party risk management. Prior to Microsoft Svatava was in private practice at international law firm Norton Rose Fulbright, where she gathered broad experience in advising global companies on risk management and compliance strategies. 


Alun joined the Crown Prosecution Service in 1992 and was assigned to work as a prosecutor in central London. There, he dealt with the full range of inner-city crime and became one of the Crown Prosecution Service’s first higher courts advocates. He moved to the Attorney General’s Office in 2004, where at various points he was responsible for the Law Officers’ casework on coroners, contempt of court and unduly lenient sentences.

In 2007 he joined Revenue and Customs Prosecutions Office where he established and led its Asset Forfeiture Division. He returned to the Crown Prosecution Service three years later and became its Head of Organised Crime, a post he held until 2012 when he moved to the Serious Fraud Office as its General Counsel. As such and for the following six years he was directly responsible to the Director of the Serious Fraud Office for all its casework.

Alun joined Kingsley Napley as a partner in February 2019. He is based in its criminal litigation department where he advises on the full range of criminal law issues with a particular emphasis on economic crime.


Anne Riley has recently retired as Head of Royal Dutch Shell’s global antitrust group, which she led since September 1992 (having practiced as an antitrust lawyer since 1985) and was a member of Shell’s Group Ethics and Compliance Office Leadership Team until her retirement.

For several years Anne has been (and continues to be) Chair of the International Chamber of Commerce (ICC) Task Force on Antitrust Compliance and Advocacy (which produced the ICC Antitrust Compliance Toolkit in 2013 and the SME Compliance Toolkit in 2015, and which engages in antitrust advocacy around the world).

Anne is a Non-Governmental Adviser (NGA) to the European Union (DG COMP) for the International Competition Network.

Anne was awarded “Women in Compliance – Compliance Innovator of the Year” in 2015. In 2013 Anne was named “In-house lawyer of the year” (Energy & Infrastructure) at the Chambers UK Women in Law Awards. Anne’s team in Shell was awarded ILO global In-house Antitrust Team of the Year award in 2008 and shortlisted for the same award in 2014. The team was also shortlisted for “Competition Team of the Year” at the 2016 British Legal Awards. In September 2019, Anne accepted an award in Washington DC (on behalf of the ICC) for contributions to Antitrust Compliance from the Society for Corporate Compliance and Ethics.


Anton Alferov is a Senior Counsel and Regional Compliance Counsel with Halliburton. He graduated from the Moscow State Law Academy in 1997 and received his Ph.D. in law from the Institute of State and Law of Russian Academy of Science. In 1997 - 2010 Mr. Alferov has been involved in the management of international development and anti-corruption projects activities in Russia. Since 2011 Mr. Alferov is responsible for implementation of the Halliburton compliance program in countries of Western and Eastern Europe, Caspian and Sub-Saharan Africa‚ including but not limited with revision of contracts in terms of compliance to FCPA‚ UK Anti-Bribery Act‚ domestic legislation‚ conducting Due Diligence on vendors‚ assure compliance with legislation on IP‚ personal data protection‚ labor law‚ etc. He is also responsible for development and implementation of compliance training program in the Region and periodic compliance audit in the countries of the Region. 


Rebecca Walker is a partner in the Santa Monica, California office of Kaplan & Walker LLP, a law firm that assists organizations in developing, implementing and improving their corporate compliance and ethics programs. For over twenty years, Ms. Walker has specialized in advising clients on the development and implementation of compliance and ethics programs that are tailored to each client's legal risks and business needs and that conform to applicable government requirements and pronouncements. Ms. Walker has counseled numerous companies in diverse industries on the various components of their compliance and ethics programs, including:

  • Assisting organizations in effectively structuring their programs;
  • Drafting and revising codes of conduct and other policies and procedures, including conflicts of interest and anti-corruption policies and procedures;
  • Developing and delivering compliance training and assisting in the development of compliance training and communications plans;
  • Developing reporting systems, investigations procedures and investigations training; and
  • Developing risk assessment processes and conducting compliance risk assessments.

Ms. Walker has also conducted numerous assessments of compliance and ethics programs, including assessments of entire programs as well as “deep dive” assessments of program elements, such as investigations procedures and program structure, and subject matter areas, such as conflicts of interest and anti-corruption programs.  She has also served as a monitor for the Department of the Air Force and as an independent consultant reviewing programs for the U.S. Securities and Exchange Commission.

Ms. Walker’s clients have included companies from the oil and gas, government contracting, engineering/construction, energy, financial services, pharmaceutical, health care, banking, automotive, publishing, advertising, consulting, telecommunications, retail, consumer products, apparel, railroad and shipping industries, among others, including many companies in the Fortune 500.

Ms. Walker chairs the Practising Law Institute's annual Compliance and Ethics Essentials program in New York and co-chairs their annual Advanced Compliance and Ethics Workshop.  Ms. Walker serves on the Advisory Board of the Compliance and Ethics Professional Magazine, published by the Society of Corporate Compliance and Ethics (SCCE) and on the Editorial Board of the Complete Compliance and Ethics Manual. For seven years, Ms. Walker served on the Advisory Board of the SCCE, the largest association of compliance professionals in the world.  For many years, she also served on the Advisory Board of the Corporate Compliance Center at the South Texas College of Law. Ms. Walker is the author of Conflicts of Interest in Business and the Professions: Law and Compliance, published by Thomson West in 2005.  She is the co-author of a number of compliance surveys, published by The Conference Board, the SCCE and others. Ms. Walker has also published numerous articles regarding compliance and ethics.  Ms. Walker is a frequent speaker on compliance and ethics issues, including for the Practising Law Institute, the SCCE, The Conference Board, and other legal and business groups.

Ms. Walker received her B.A. (magna cum laude, Phi Beta Kappa) from Georgetown University and her J.D. (cum laude) from Harvard Law School. 


Stephanie is counsel in our New York office. She advises clients in connection with US economic sanctions, export controls and defense trade controls, the US Foreign Corrupt Practices Act (FCPA), US anti-money laundering law, and global business and human rights. Her experience also includes cross-border public and private M&A, private equity transactions, venture capital and general corporate governance.

Select experience includes:
• advising several multinational companies and financial institutions on the implications of Iran sanctions relief under the Joint Comprehensive Plan of Action;
• advising a number of companies and financial institutions based in Europe, the United States or Russia in relation to US economic sanctions imposed in 2014 relating to the situation in Ukraine;
• advising a major global private equity firms on the application of US economic sanctions, export controls and the FCPA in relation to investments and acquisitions;
• advising a European-based, multinational automotive company on the applicability of and compliance with US economic sanctions and export controls in its worldwide business activities; and
• International General Insurance Holdings Ltd., a private Dubai-based insurance company, in its merger with Tiberius Acquisition Corporation, a Nasdaq-listed US special purpose acquisition company.

 


A senior and respected global ethics and compliance professional with 20 years experience of building,
running and leading ethics and compliance teams and programmes.

Works in medium to very large international businesses in numerous sectors including: energy, utilities,
manufacturing, oil and gas, mining, financial information and news, technology, industrial gases, materials
handling and logistics.

Designs, builds and manages ethics and compliance programmes covering all aspects - including risk
management programmes, codes of conduct, whistleblowing lines, corporate values, training, ethics
registers and all investigations. Manages and leads functions and teams of all sizes up to 125 people,
including global functional re-organisations. Has managed and rationalized functions and programmes in
challenging cost environments.

Designs and implements tailored programmes to ensure bribery, competition/anti trust, money
laundering, trade regulation/sanctions, data protection and conduct risks are effectively managed. Has
wide experience in bribery risk, creating ABC programmes from scratch in global multinationals and
having worked with the UK Government (Ministry of Justice) during the creation of the Bribery Act,
helping to draft the adequate procedures guidance.

Has managed disclosures and notifications to various global regulators in numerous jurisdictions around
the globe. Has selected, on-boarded and facilitated the work programmes of monitors appointed by
various U.S. Government Departments (Department of Justice, Securities and Exchange Commission and
Environmental Protection Agency).

Qualified as a Barrister in 1991 and as a Solicitor in 1998.


Ali is a partner in our corporate crime group and co-head of our global investigations practice in London.

With a record of acting on major cross-border and domestic investigations for clients in all sectors, she specialises in corporate and financial crime defence and regulatory enforcement actions, particularly defending actions brought by the UK Serious Fraud Office (SFO) and/or Financial Conduct Authority (FCA), as well as overseas authorities.  

Ali has significant expertise handling false accounting, fraud, bribery/corruption, money-laundering and terrorism-related matters. She has acted on many of the leading enforcement decisions brought by the FCA, especially in market abuse, market manipulation, and disclosure and listing obligations cases.  

Ali is recognised as a leading individual in corporate crime, contentious financial services and global investigations by all major directories.

Ali is a sector group leader of Freshfields' London pro bono practice and a trustee of the RCJ Advice Bureau.


Ben is a Senior Associate in Baker McKenzie's IPTech team, based in London.

Ben is a Certified Information Privacy Professional (CIPP/E).

Ben advises on data protection, e-commerce/digital media and consumer law. Ben advises clients in wide range of industry sectors on data protection compliance, including consumer facing business, healthcare, financial services, AdTech, business to business organisations, and pension scheme trustees.

Ben regularly assists clients with global data protection compliance projects and assessments as well as specific data protection challenges such as international transfers and data security breaches. Ben is also regularly involved in drafting and negotiating data protection clauses and agreements for various clients in a wide range of industry sectors. Ben also regularly advises clients on electronic direct marketing and cookies.


Lauren is a Director within Deloitte’s Risk Advisory business specialising in Regulatory Risk. Her primary focus is as a risk and compliance specialist focussed on designing and implementing frameworks and advising clients on how to gain better line of sight over the management of their risks. Having worked in industry and re-joined Deloitte in May 2013, she has over 15 years of experience across Governance, Risk, Controls and Assurance.

 

As part of Lauren’s specialism she has particular experience in:

 

  • Setting up and running Ethics & Compliance functions. Designing and implementing the target operating model which includes establishing the structure, people, processes, technology and data required to run an effective function and report to management
  • Establishing Governance, Risk & Control frameworks with significant experience in the Information Risk Management space.
  • Regulatory and compliance issues across a broad range of topics with experience in helping assess the culture of compliance, writing Code of Conducts and assessing and designing corporate whistleblowing and speak up processes.

 

Lauren has held roles across a large range of industries but has deep industry specialism within Energy and Resources having worked alongside Oil and Gas supermajors for the last 11 years. As a result of this Lauren has a wealth of experience across all aspects of a vertically integrated organisation and has operated at the most senior level of these organisations. 

 


Andrew is Group Head of Compliance and Ethics at Subsea 7 SA, a global leader in the delivery of offshore projects and services for the evolving energy industry. Its clients include national and international oil companies all over the world. Subsea 7 is listed on the Oslo Stock Exchange and headquartered in London.

Andrew is also co-author (with Tony Osborn) of The Business Guide to Effective Compliance and Ethics: Why Compliance isn’t Working - and How to Fix it, which was published by Kogan Page on 3 August 2019 .

He worked with the British Standards Institute on the development of the first anti-bribery standard (BS10500) and was part of the UK delegation on the development of the International Anti-Bribery Standard (BS ISO 37001:2016).

From April 2009 to December 2013 Andrew was Head of Ethics and Compliance at Balfour Beatty plc, a UK-headquartered global infrastructure services company. His role involved working closely with the independent compliance monitor appointed following the company’s 2008 civil settlement with the UK Serious Fraud Office. 

From 1999 to 2009 he worked for AstraZeneca PLC, the major UK-headquartered pharmaceutical company, in Cheshire (UK), Delaware (US) and the London corporate head office, where he become Chief Counsel, Global Compliance in 2008.

After graduating from New College, Oxford with a Joint Honours Degree in Modern Languages, Andrew did the law conversion course at The College of Law and joined Clifford Chance in 1989, where he qualified as a Solicitor in 1991. He spent 10 years as a corporate lawyer in private practice, at Clifford Chance (London and Paris), Clyde & Co (Dubai) and Addleshaw Goddard (Manchester), specialising in private equity and mergers and acquisitions.

Andrew is married to a lawyer and is the father of two grown boys.

September 2019

 


Christine Braamskamp is based in London and serves as co-chair of the firm’s Investigations, Compliance and Defence Practice at Jenner & Block, a US-headquartered international litigation and transactional law firm.  A leading lawyer in multi-jurisdictional white collar cases, Ms. Braamskamp has extensive experience with significant and high-profile trials and other court matters, as well as internal investigations.  She has represented corporates and senior management individuals facing UK Bribery Act, FCPA and Fraud Act proceedings.  She regularly advises on FCA- and FRC-related enforcement actions and offers compliance advice, including relating to sanctions, whistleblowing and anti-bribery and corruption procedures, as well as anti-money laundering advisory work, including advising on suspicious activity reports.

Ms. Braamskamp started her career as a legal aid criminal defence lawyer in the mid-nineties.  Formerly a Barrister at the pre-eminent Chambers of Alexander Cameron QC at 3 Raymond Buildings, she is a highly experienced trial lawyer.  Ms. Braamskamp regularly represents Dutch nationals who face criminal proceedings in England and Wales and advises on criminal proceedings in the Netherlands.  Having practised in the Netherlands, she has extensive experience in the civil law system.

Ms. Braamskamp is regularly recognized for her work and by her peers.  She is featured in The Lawyer's Hot 100 2019, an annual report gathering of "the most daring, innovative and creative lawyers from in-house, private practice and the Bar" and Global Investigations Review’s Women in Investigations 2018, which honours 100 investigations professionals from around the world.  She is also annually recognized by Chambers and Partners UK and Legal 500 UK.  In 2016, she was named as a “rising star” in litigation by Legal Week.

 


Holly is a Senior Associate in the People & Reward team, advising on employment issues in an advisory, transactional and contentious context.  

Holly has a number of clients in the financial services sector and advises regularly on the employment aspects of the Senior Managers and Certification Regime and the Conduct Rules.  She is particularly interested in the interaction of culture and conduct risk, and in how lessons learned in the financial services sector can be translated to the wider corporate arena, whether in relation to whistleblowing, individual accountability or the approach to measuring and seeking to improve corporate culture.

Holly’s recent experience in the financial services sector includes advising on the role of the whistle-blowers’ champion under the FCA’s whistleblowing rules, the investigation of employee misconduct under the Conduct Rules and the obligations owed by employers under the regulatory reference regime.   

Beyond financial services, Holly advises a range of corporate clients on executive remuneration issues (including the potential application of malus and clawback) and hiring and firing, as well as the employment consequences of business reorganisations.  

Holly has a particular interest in regulatory investigations and is a member of the firm’s global investigations practice.  She is a member of the Employment Lawyers Association (ELA) and sits on a sub-committee of ELA’s legislative and policy committee, focusing on #MeToo issues and responding to government and industry-led consultations on proposed changes to the legislation in this area.

Holly also advises on the employment aspects of international transactions and has experience of both public and private mergers and acquisitions, as well as restructurings.  

 


Johanna Walsh is a Partner in the White Collar Crime & Investigations Group. She has experience in domestic and international serious fraud, corruption and money laundering cases, acting for senior individuals in prosecutions brought by the SFO, FCA and CPS, as well as investigations by the NCA. Johanna has also acted for a range of corporates, from SMEs to FTSE 100 companies in relation to allegations of fraud and corruption, conducting internal investigations and representing them in external investigations and prosecutions.

Johanna is named in Legal 500 in 2018 and 2019 for Regulatory Investigations and Corporate Crime. She is named as a leading individual in Business Crime Defence in the 2019 edition of Who's Who Legal, as well as an Investigations Future Leader in Who's Who Legal's 2019 and 2018 editions, which notes that "her expertise in multi-jurisdictional investigations involving state authorities makes her a go-to practitioner."

She was also recognised in the 2017 edition of 40 Under 40 by the Global Investigations Review, recognising accomplished young investigations lawyers who will help shape the future of this fast-evolving area of law.

 


Jonathan is a highly regarded anti-bribery & corruption (ABC) risk expert with over a decade of experience in providing risk mitigation advice and training. He has implemented ABC programmes for companies under regulatory scrutiny from the US and UK authorities.
 
Jonathan joined Exiger from Tesco Plc where he was the Legal Counsel for Business Integrity. In this role, he led on various ABC risk areas including policy implementation, risk management and investigations.
 
Before this, Jonathan was a Director at GlaxoSmithKline Plc (GSK). While there, he was responsible for leading a global team of ABC risk experts. He was an ABC subject matter expert on the Due Diligence Working Group, advising on GSK’s $20bn joint venture with Novartis. Jonathan had overall responsibility for GSK’s enterprise-wide ABC training strategy, which required influencing senior stakeholders.
 
Jonathan has experience of working with commercial leadership teams and compliance professionals in over 40 countries. He has designed risk control frameworks, conducted in-market compliance assessments and advised on risk mitigation in a broad range of jurisdictions including the United Arab Emirates, China, Cambodia, Russia, Ukraine, Slovakia, Nigeria, South Africa, Vietnam, Poland, Cameroon and Ivory Coast.
 
Jonathan also practiced at a top-ranked barristers’ chambers, Red Lion Chambers, where he specialised in general crime and fraud. While there, he undertook secondments at UK magic-circle law firms, the Serious Fraud Office and the Financial Conduct Authority. Jonathan also advised the Attorney-General of the Falkland Islands on compliance with OECD regulations and anti-corruption compliance. This included a period of secondment on the islands.
 
Jonathan combines deep subject matter expertise with years of in-house experience, allowing him to provide concise and pragmatic advice coupled with solutions which are proportionate to the risks faced. His practical experience is well balanced between remediation and preventative work, and his experience as an in-house compliance expert is especially useful in helping him to quickly identify underlying issues, and to anticipate implementation challenges.
 
Education
 
Kingston University, LLB (Hons)
Bar Vocational Course, Very Competent
Queen Mother Scholar, Honourable Society of the Middle Temple
 
Affiliations, Awards, and Civic Engagements
 
Door Tenant (non-practising), Red Lion Chambers, Chambers of Gillian Jones QC and Tony Shaw QC
Leading Professional in Professional Ethics & Compliance, Ethics & Compliance Initiative


Judy Krieg is a partner in the London office of Fieldfisher.  She is a solicitor of England and Wales and a member of the New York bar. Her wide-ranging experience includes implementing compliance programmes, defending them to regulators and conducting M&A compliance due diligence.  Her clients include companies of all sizes (from worldwide conglomerates to startups) as well as public bodies.   Judy was educated in the US and spent the first 15 years of her career as a US lawyer, both in-house and in private practice.  Judy moved to the UK in 2007 and became an enforcement lawyer for the UK Financial Services Authority. She subsequently moved in-house, becoming Microsoft's sole Compliance Lawyer for Europe and Russia.  Judy has held two global Chief Compliance Officer roles (Rolls-Royce plc and Willis Group Holdings) before returning to private practice.  Her first hand experience includes US DOJ and UK SFO assessment of compliance programmes.


Paul has 25 years of experience working in a variety of roles focused on legal process improvement. As a young lawyer Paul noted the significant potential for technologies such as email, databases, networks and digitisation to improve lawyers’ efficiency. Since then, Paul’s career has focused on identifying ways to identify and adapt technology tools to improve legal processes in a variety of contexts. 

During this time, the adoption of technology has evolved from the realm of early adopters to a widely recognized necessity for most lawyers, and an arms race between business, regulators and those who break the rules. 

Paul and his team help law firms and in-house legal teams overcome the various data challenges that arise in cross-border disputes and investigations, and applies the experience acquired in this work to help clients improve the efficiency of their compliance programs.

Paul qualified from American University in Washington, D.C. He has lived and worked in the United States, France, and the United Kingdom, and speaks French and Spanish.

Relevant Experience
• Assisted a corporate client that had recently revamped its ethics and compliance program, including the addition of a whistleblower hotline. Following a steep spike in reports (mostly uncorroborated), Paul addressed initial improvements to the program by integrating suitable search analytics. This was followed by an in-depth examination of the tools necessary to integrate into the company’s cloud-based platform to streamline the data acquisition process, with a particular focus on data protection requirements such as minimizing data movements and unnecessary processing.
• Managed data acquisition as part of the monitor team for a bank, focusing on KYC and AML procedures. Consolidated data from email, file servers and databases to implement a comprehensive look-back system that enabled an efficient and detailed review of the information available to the bank’s various departments at any point over the multi-year period under review. This approach enabled the reviewing team to efficiently assess the adequacy of the reviews undertaken by the bank, and to highlight deficiencies in detail for our final report. 
• Based on a workshop with a client to assess the long-term objectives for its ethics and compliance program, Paul recommended a redesign of the review process. This included a revision of the search process by integrating search analytics, predictive modeling to accelerate the review, and performance management metrics to track quality. After implementing these recommendations, and with no addition to the team and a modest increase in the yearly budget, the number of people included in the reviews expanded by 400%, and could be completed by examining only 20% of the information available for review.