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Corporate Compliance and Ethics Institute 2014


Speaker(s): Andrew J. Hinton, Ed Petry, Gary F. Giampetruzzi, James R. Turner, Janice L. Innis-Thompson, Jeannie Rhee, Jeffrey M. Kaplan, Jennifer Heller, Jim Nortz, Kathryn S. Reimann, Kathy Rehmer, Maria C. Hermida, Mark Ehrlich, Nora Kurzova, Paul E. McGreal, Seth M. Cohen, Stephen C. King
Recorded on: May. 29, 2014
PLI Program #: 51084

Andy Hinton is the Vice President of Global Ethics and Compliance at Google. In this role, Mr. Hinton leads the company’s efforts to identify and mitigate compliance risk and to nurture and expand upon the company’s core value of “Don’t be evil.”

Mr. Hinton joined Google in November 2006. From 2003 to 2006, Mr. Hinton was the Chief Compliance Officer at two GE Capital financial services businesses. From 1994 to 2003, Mr. Hinton was a federal prosecutor in New York City, focusing on white-collar crime. From 1989 to 1994, Mr. Hinton was a litigation associate at the New York City law firm of Cravath, Swaine & Moore, where he focused on commercial litigation and white-collar criminal defense.

Mr. Hinton is a 1989 graduate of Fordham School of Law, where he was a member of the Law Review, and a 1982 graduate of Harvard University, where he majored in Economics.

Mr. Hinton lives in Palo Alto, California with his wife, Joy, an accomplished securities lawyer, and their two children, Sarah and Eric.


Jeffrey M. Kaplan is a partner in the Princeton, New Jersey office of Kaplan & Walker LLP.   For twenty-five years he has specialized in assisting companies in developing, implementing and reviewing corporate compliance/ethics programs. This work has included conducting risk analyses; writing/editing codes of conduct and other policy documents; counseling companies in matters regarding training; developing compliance audit protocols and reporting systems; establishing compliance/ethics offices; and assisting boards of directors in meeting their fiduciary duties under the Caremark case.  He has also conducted numerous program assessments. Mr. Kaplan’s compliance/ethics program practice has included work for clients in the health care, medical devices, pharmaceuticals, automotive, government contracting, insurance, manufacturing, energy, retail, paper, publishing, professional services, education, consulting, telecommunications, technology, securities, private investments, food and chemical fields, as well as non-profit organizations. 

Mr. Kaplan has, on three occasions, been an independent consultant for companies suspended by the World Bank, reporting to the Bank on their respective compliance programs, and performed a similar review for the United Nations; has served as a compliance monitor in a criminal tax case for the New York County District Attorney; has reviewed and reported to the Department of Justice and SEC on a company’s compliance/ethics program in connection with the settlement of an FCPA-related investigation; and has reviewed and reported to a state attorney general on another company’s compliance/ethics program in connection with a settlement of a fraud-related matter.  He also conducts internal investigations on behalf of boards and companies into allegations of wrongdoing brought by whistleblowers and others.  He received his B.A. (magna cum laude, Phi Beta Kappa) from Carleton College in 1976 and his J.D. (cum laude) from Harvard University in 1980.  He is a former partner of Chadbourne & Parke, where he served in the Special Litigation Group, and also a former partner of Arkin Kaplan & Cohen LLP and of Stier Anderson, LLC. 

For many years Mr. Kaplan was Counsel to the Ethics Officer Association (now the ECI), a professional association of more than 1000 compliance/ethics officers.  He is, together with Joe Murphy, co-editor of Compliance Programs and the Corporate Sentencing Guidelines: Preventing Criminal and Civil Liability (West 1993), a leading legal treatise on designing and implementing compliance/ethics programs.  He is author of an e-book on risk assessment issued by Corporate Compliance Insights.   He is editor of the Conflict of Interest Blog.  He was for many years Adjunct Professor of Business Ethics at the Stern School of Business, New York University.  He is now a contributor to the Ethical Systems research project which is run by a professor at that school, and has recently co-authored an e-book for Ethical Systems on behavioral ethics and compliance. He is a member of the New York and New Jersey bars.


Jennifer Heller is Vice President, Chief Compliance Officer, and Senior Deputy General Counsel for Comcast Corporation.  In this role, she is responsible for leading the internal processes for promoting and ensuring Comcast’s compliance with laws, regulations, company policies and contracts, including chairing its enterprise-wide Compliance Committee which oversees its compliance risk management and internal complaint reporting programs.  She is also responsible for formulating and implementing Comcast’s policies and procedures, including its Code of Conduct, and making sure they are communicated and trained upon across the company. 

Comcast Corporation is a global media and technology company with two primary businesses, Comcast Cable and NBCUniversal. Comcast Cable is one of the nation’s largest video, high-speed Internet and phone providers to residential customers under the XFINITY brand and also provides these services to businesses. NBCUniversal operates news, entertainment and sports cable networks, the NBC and Telemundo broadcast networks, television production operations, television station groups, Universal Pictures and Universal Parks and Resorts.


Kathryn Reimann, Senior Managing Director and Service Area Executive with Treliant, has wide-ranging experience as Chief Compliance Officer and In-house Counsel at some of the world’s premier financial services companies—in retail and commercial banking, payments, investment banking, and securities trading.

At Treliant, Kathryn is the senior executive overseeing the Consumer Compliance service areas. She is responsible for the service area strategies, including their expansion and client services.

Prior to joining Treliant, Kathryn was Chief Compliance Officer and Managing Director at Citibank, N.A., and Citi’s Global Consumer Bank. She led the compliance functions of both entities, including retail and commercial banking, credit card, secured and unsecured lending, and other consumer finance and investment businesses.

She also served as Senior Vice President and Chief Compliance & Ethics Officer at American Express. Previously, she was Senior Vice President, Chief Compliance Officer, and Senior Counsel at the Lehman Brothers investment bank. She has also worked as an attorney in the General Counsel’s Office of the Dean Witter Reynolds securities brokerage and with the law firm of Curtis, Mallet-Prevost, Colt & Mosle.

Kathryn has a JD from New York University’s School of Law and a BA from Princeton University’s Woodrow Wilson School of Public and International Affairs.


Mark Ehrlich is Vice President, Global Ethics and Compliance at Hilton. Mark is responsible for all aspects of Hilton’s global corporate compliance program, with a particular focus on anti-corruption laws and international trade restrictions, as well as Hilton’s data privacy and security programs.  He oversees third party due diligence, internal investigations, ethics and compliance training, as well as information security risk assessments and incident response.

Prior to joining Hilton, Mark served in compliance roles with The AES Corporation, a global power company, and with MCI/WorldCom where he participated in developing an ethics and compliance program following the discovery of WorldCom’s financial improprieties.  In addition to his work in the ethics and compliance field, Mark has extensive litigation and regulatory experience, serving as in-house counsel with the MCI regulatory litigation group, attorney advisor at the Federal Communications Commission (FCC), and trial attorney with the U.S. Department of Justice in the Civil Division’s Commercial Litigation Branch.


Nora Kurzova  has been with Tyco since 2007. She has served in multiple roles including Commercial Lawyer for Eastern Europe, Compliance Counsel EMEA and most recently is Chief Privacy Officer for Tyco globally.

Nora started her academic career with undergraduate studies of Law and Forensic Science at the Police Academy in Prague, then earned her masters in general law at Charles University in the Czech Republic followed by post graduate studies and a doctoral degree in Criminal law and forensic science.  She then completed LLM degree in International Public and Criminal law from  the University of Greenwich, UK. Currently Nora is enrolled in a non-degree program and is studying Cryptography and Computer Science at Princeton University.

Nora speaks English, Czech, Russian, French and Slovak and her area of expertise next to data privacy and data protection is criminology with a focus on regulation of corruption and fair competition.

Before joining Tyco Nora has worked for the Czech Criminal Police  where she assisted investigations of organized crime and also taught Introduction to Law and Forensic Science at a Mensa gymnasium in Prague.

Nora has contributed to various periodicals in the Czech Republic on regulation of corruption and has developed a standard on Collecting and Handling DNA evidence for the Department of Forensics in the Czech Republic.


Paul E. McGreal is a Professor of Law at the Creighton University School of Law. He came to Creighton in July 2015, as dean of the School of Law, and he served in that position through July 2017. He is Compliance Adviser to the Omaha Business Ethics Alliance, and he teaches a course on leadership and conflict engagement in Creighton’s Master’s program in Negotiation and Conflict Resolution.

Professor McGreal also teaches in the Texas A&M University Executive and Professional MBA Programs.  His courses there have included modules on corporate vicarious liability, domestic and foreign anti-corruption laws (including the Foreign Corrupt Practices Act), corporate compliance and ethics programs, business ethics, and corporate governance.

Professor McGreal was previously dean of the University of Dayton School of Law from 2011 to 2014.  Before that, he was associate dean and professor of law at Southern Illinois University School of Law, where the graduating class voted him the Senior Class Award in 2008, 2009, and 2010.

Prior to joining SIU, Professor McGreal established the Corporate Compliance Center at the South Texas College of Law, where he taught for 10 years.  While at South Texas, he created and taught the first course on corporate compliance and ethics programs offered at a United States law school. 

Professor McGreal is a frequent speaker and commentator on corporate compliance and ethics programs, and he authors an annual survey of legal developments on the subject for The Business Lawyer, published by the Business Law Section of the American Bar Association. He has also published over 40 articles and essays in law journals at schools including University of Notre Dame, Northwestern University, and the University of Pennsylvania.

Before teaching, he worked in the Dallas office of Baker Botts LLP. After graduating from law school, he served as law clerk for Justice Warren Matthews of the Alaska Supreme Court.

 

Professor McGreal earned an LL.M. from Yale Law School, a J.D. from the Dedman School of Law at Southern Methodist University, and a B.A. in economics from Williams College.


Seth Cohen was most recently the Vice President & Managing Counsel for Global Compliance for ADP, LLC.  He was with ADP from January 2017 to June 2019.  Seth’s responsibilities included the day-to-day management of the Core Compliance team, with a particular focus on key activities such as compliance risk assessment, compliance technology enablement, monitoring, reporting and supporting policy, training and communication initiatives.  Prior to joining ADP, Seth was a Director with the Risk Management & Compliance Solution’s practice of PricewaterhouseCoopers (PwC) from 2014 to 2017.  At PwC, Seth advised clients on their compliance and ethics programs, conducted compliance risk assessments and developed codes of conduct and other compliance and ethics policies and procedures.  From 2012 to 2014, Seth was the Director of Global Ethics & Compliance at Avaya, Inc., where he managed the company’s global ethics and compliance program.  From 2006 to 2012, Seth was Head of Policy and Processes for Zurich Financial Services’ Office of Compliance North America, where he assisted in the development of the regional compliance function and supported Zurich's response to its regulatory settlement agreements.  Seth also led the company’s global practice group on competition and antitrust, and provided compliance support to Zurich's alternative asset management group.  Prior to arriving at Zurich, Seth was a manager in the Forensic practice at KPMG from 2001 to 2006, where he conducted investigations and compliance and governance assessments for Fortune 500 companies.  He began his career as an Assistant District Attorney in Bronx County, NY, and followed that experience as an investigative attorney for the New York City Department of Investigation.  Seth is a Certified Fraud Examiner (CFE) and is a member of the Association of Certified Fraud Examiners, the Ethics & Compliance Initiative and the Society of Corporate Compliance and Ethics. Seth has published several articles in external publications and spoken on a variety of topics, including compliance program development, antitrust compliance and social media.  Most recently, Seth was one of the co-authors of PwC’s 2016 State of Compliance study as well as the PwC paper, Trends in compliance organizational structures.  Seth is a graduate of the Massachusetts Institute of Technology and the George Washington University Law School.


Work Experience

Alabama Power Compliance and Concerns Director – Provides oversight for the design, implementation, enforcement, and modifications of Alabama Power’s overall compliance and employee concerns programs.  This includes ensuring that designated and qualified resources exist for each compliance risk area (team leaders and business unit coordinators), that overall compliance education/training is adequate for board members, executive management, facility/department management, and compliance personnel, and that all employee concerns are appropriately investigated and resolved.  Also chair of Company’s Investigative Review Committee (IRC) which provides oversight and cooridination of all company investigations.  Alabama Power provides electric service to 1.5 million customers in the State of Alabama, has total revenues of $6 billion dollars, and has 6,700 employees.  (2004 to Present)

Southern Company Generation Compliance Director – Overall Compliance Program coordination / management for Southern Company Generation.  Southern Company Generation is responsible for the management of the Southern Company’s Generation Fleet – over 80 generating plants producing over 42,000 megawatts of power.  (2002-2004)

Southern Company Internal Auditing - Compliance Director - As Compliance Audit Director, responsible for assessing compliance risks for Southern Company and for managing compliance audits of all Southern Company subsidiaries (environmental, safety and health, employment, etc.).  During audit career, performed and managed all types of audits including operational, financial, compliance, management requests, and fraud investigations.  Environmental auditing experience began in 1981.  (1975 – 2002)

Other Activities:

  • Board of Environmental Auditor Certification (BEAC) Board of Directors. (2002-2008)
  • American Chemistry Council Responsible Care Technical Oversight Board – Member of Board responsible for oversight of Responsible Care, 3rd party certification program within the U.S. Chemical Industry.(2003-2008)
  • Edison Electric Institute (EEI) Peer Review Program Director - Director of Peer Review Program that provides for the evaluation of a member utility’s environmental audit program. (1997-2000)
  • EEI Environmental Auditing Taskforce Vice-Chairman (1994-1996)
  • United States Energy Association - Part of delegation that conducted environmental management and auditing seminar for four Eastern Europe countries in Slovakia (1995) and in Atlanta (1996)

Education / Certifications

  • B.S. Accounting, University of Alabama
  • Certified Internal Auditor (CIA), Certified Professional Environmental Auditor (CEPA) and Certified Fraud Examiner (CFE)


Jim Nortz is an attorney and a nationally recognized expert and thought leader in the field of business ethics and compliance with over a decade of experience in the field of healthcare compliance serving multinational pharmaceutical and medical device corporations.

Jim spent the first 17 years of his career as a litigator and corporate counsel before becoming Crompton Corporation’s first Vice President, Business Ethics and Compliance in 2003.

Since then, Jim has served as a compliance officer at Crompton and for five other multinational corporations, the most recent of which was as Chief Compliance Officer at Carestream Health. Jim has extensive experience in implementing world-class compliance and ethics programs sufficiently robust to withstand US Department of Justice scrutiny.

Jim is a frequent guest lecturer at the University of Rochester’s Simon School of Business, RIT’s Saunders School of Business, St. John Fisher College, Nazareth College and other law schools and universities around the country.

Jim writes the monthly business ethics columns for the Association of Corporate Counsel Docket magazine and the Rochester Business Journal.

Jim is a member of the National Association of Corporate Directors and serves on Conscious Capitalism ROC’s Steering Committee. Previously, Jim served on the Board of Directors for the Ethics and Compliance Officers Association (“ECOA”) and the Board of the Rochester Area Business Ethics Foundation.

Jim is currently Founder & President, Axiom Compliance & Ethics Solutions LLC, a firm dedicated to driving ethical excellence by helping organizations implement effective compliance and ethics programs.

 


Kathy has been with AT&T or it predecessor companies for over 35 years.  Since 1990 she has been involved in some type of compliance function, from Regulatory Compliance to Corporate Compliance & Ethics.  Among her accomplishments, she created a new compliance program for Cingular Wireless, successfully completed a major code rewrite at AT&T and created an Integrated Governance Council to analyze ethical violations across the organization.  On her current job, she is responsible for AT&T’s Compliance & Ethics Program. 

Kathy is married, with 2 grown sons and a daughter who just started college last fall. 


Janice Innis-Thompson is the Chief Compliance Officer for Samsung Electronics North America, a role she took on in April 2017.  For approximately eight months prior to joining Samsung, Janice worked as a Senior Advisor for Compliance Strategies, a leading consulting firm specializing exclusively in compliance, ethics, risk and governance practices.  Until June of 2016, Janice was the Chief Compliance and Ethics Officer for TIAA, a role she served in for nine and a half years. Ms. Innis-Thompson oversaw and managed TIAA’s enterprise wide compliance and ethics program. She led a team of compliance professionals who transformed TIAA’s Compliance Program from an Insurance-centric program to a multi-regulated program driven by the Federal Reserve Bank.  She also created TIAA’s Ethics program, which won Ethisphere’s Awards in 2014, 2015 and 2016 ranking TIAA as one of the most Ethical Companies in the World.

Ms. Innis-Thompson joined TIAA in October 2006 from Tyco International, where she was Chief Compliance Counsel. Prior to that, she was the Chief Compliance Counsel at the International Paper Company. Ms. Innis-Thompson began her career with the United States Department of Justice, where she was an Assistant U.S. Attorney in three jurisdictions. During that time she also served a year as Counsel to the Director of EOUSA (Executive Office for United States Attorneys), and worked with Attorney General Janet Reno during the 1996 election. Ms. Innis-Thompson holds a B.A. with honors and a J.D. from the University of Florida. She is a board member of Edward Jones’ Bridge Builder Trust Fund, where she chairs the nominating and governance committee. She is also the Vice President of the Board of the Wardlaw-Hartridge School and she chairs the Committee on Trustees for the School.  Janice is an active member of several industry groups including the Compliance & Ethics Leadership Council and the Executive Leadership Council.  She lives in NJ with her husband, Stephen Lawrence and their daughter Kelly.


Ed Petry, Ph.D., joined NAVEX Global Advisory Services in 2004 after almost ten years as executive director of the Ethics and Compliance Officer Association (now part of ECI).  Ed served on the Advisory Panel to the U.S. Sentencing Commission which was responsible for the 2004 revisions. Earlier in his career he was a tenured professor of ethics and a prolific author and researcher and served on various boards and oversight committees for ethics organizations including the Ethics Oversight Committee for the U.S. Olympics. As Vice President with Advisory Services, Ed applies his more than 30 years of experience to help companies assess their ethics and compliance programs. He has also helped more than 250 companies develop and improve their codes of conduct.


Gary F. Giampetruzzi is a partner in the Litigation Department of Paul Hastings, based in the firm’s New York office. Prior to joining Paul Hastings, Mr. Giampetruzzi most recently served as Vice President, Assistant General Counsel and Head of Government Investigations at Pfizer Inc, with responsibility for government investigations across the company’s multiple business units and operations globally, and associated government litigation with U.S. and international prosecutor offices. He was previously a Deputy Compliance Officer responsible for international compliance investigations and programs with responsibility for the implementation and maintenance of compliance programs and systems across the company's international operations, with an enhanced focus on emerging markets. He routinely advises clients on day-to-day compliance matters, and represents corporations in high-profile federal and state investigations, including those involving federal and state False Claims Act (qui tam suits), State Attorney General consumer protection statutes, the Foreign Corrupt Practices Act (“FCPA”), and oversees other complex civil and criminal litigation matters.

Mr. Giampetruzzi is highly regarded by counsel, healthcare industry insiders, and regulators for his strategic thinking and sound judgment in handling some of the most significant regulatory investigations in the pharmaceutical industry in recent years. He understands how to engage appropriately with the regulators, and how to litigate effectively when that should become necessary. He brings unique experience and perspective to each client representation, having himself been the client for more than a decade at one of the largest multi-national corporations in the world. During that time, he partnered closely with his business colleagues and various platform functions, and helped navigate a complex organization through some of the most significant compliance and enforcement issues faced in the pharmaceutical industry. As a senior leader, Mr. Giampetruzzi routinely operated at the executive leadership team and board levels, and understands from his firsthand experience that the particular needs of each client and circumstance are different, and that the approach and solutions must be too. Mr. Giampetruzzi genuinely appreciates the pressures and realities facing clients and in-house counsel, and works with them to understand and achieve their specific goals.

Mr. Giampetruzzi has extensive experience with all facets of the anti-corruption and FCPA landscape. He has been a leader in this growing area of practice for more than a decade, having led the development of cutting edge compliance programs and measures, conducted and overseen hundreds of internal investigations, and been on the ground in more than 40 markets worldwide (including Asia, Africa, Europe, the Middle East, and Latin America). He was instrumental in the development of proactive market review approaches that have been incorporated into recent government resolutions, and acquisition due diligence techniques that were cited in the Justice Department’s FCPA Guidance document. He has the proven and longstanding ability to provide end-to-end support, from front-end compliance counseling and program build-outs and enhancements, to the efficient conduct of global internal investigations, to the defense of companies before U.S. and international authorities, while keeping an appropriate eye towards the increasing risk of follow-on civil litigation.

Recent Representations

  • Mr. Giampetruzzi has also been a practice leader in the U.S. healthcare enforcement area, having been in the middle of some of the most significant cases to date.
  • Oversaw the negotiations, finalization of terms and preparations for the announcement of the landmark $2.3 billion civil and criminal, off-label promotion and kickback investigations with the Boston, Philadelphia, and other U.S. Attorney’s Offices, Main Justice, HHS OIG, and State Medicaid Fraud Control Units (largest criminal case in history at the time) and the $491 million civil and criminal, off-label promotion investigation with the Western District of Oklahoma U.S. Attorney’s Office, Main Justice, HHS OIG, and State Medicaid Fraud Control Units.
  • Oversaw the negotiation and resolution of the grand jury investigation into the promotion of the $10 billion in sales, drug Protonix by the Boston U.S. Attorney’s Office, achieving a novel, civil-only resolution entailing $55 million in disgorgement under the Food, Drug, & Cosmetics Act.
  • Oversaw internal investigations and associated voluntary disclosures under the FCPA for a pharmaceutical company involving numerous markets around the world to the U.S. Department of Justice and SEC, and certain foreign authorities, beginning in 2004, and concluding in 2012. Secured a full declination for the parent company, a deferred prosecution agreement for the relevant corporate subsidiary, no imposition of an independent monitor, and explicit government recognition of the company’s efforts.
  • Oversaw the acquisition due diligence, resultant internal investigations in numerous markets and associated voluntary disclosures to the U.S. Department of Justice and SEC, which resulted in a full declination for the parent company and subsidiaries, and a purely civil resolution.
  • Defended a pharmaceutical company against government inquiries and investigations by the Chinese Administration of Industry and Commerce (“AIC”) in Beijing, Shanghai and other cities and provinces across China.
  • Oversaw the defense and resolution of numerous whistleblower qui tam suits involving claims under the False Claims Act and related state statutes.
  • Oversaw the successful resolution of several individual State Attorney General and multi-state AG coalition matters, including the $33 million consumer protection settlement with a coalition of 44 states around the promotion of Geodon, and the $45 million consumer protection settlement with coalition of 34 states around the promotion of Zyvox and Lyrica.
Accolades and Recognitions

Mr. Giampetruzzi brings creative lawyering to bear on each of his client’s challenges, with some of the compliance approaches he developed having become a best practice (e.g., proactive FCPA market reviews, now routinely in government resolutions), and even being cited in the U.S. government’s FCPA guidance document (e.g., FCPA acquisition due diligence).

Speaking Engagements and Publications
  • Mr. Giampetruzzi is a frequent speaker at industry conferences on a variety of white collar defense topics, including global compliance programs, government investigations, state and federal U.S. healthcare enforcement, and the Foreign Corrupt Practices Act.
  • Program Faculty, Seton Hall Law School, U.S. Healthcare Compliance Program
Education

Saint John’s University School of Law, J.D., 1993