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Advanced Compliance and Ethics Workshop 2015

Speaker(s): Alex Sleightholme, Andrew J. Hinton, Carl R. Goldberg, Chad A. Fentress, David C. Farrell, David I. Greenberg, Gina Saviola, Grace Kendrick, Jeremy Wilson, Larry Pennino, Leonard H. Shen, Lupe Garcia, Nancy Higgins, Pamela R. Davis, Paul E. McGreal, Ravi Inthiran, Rebecca Walker, Steven Priest
Recorded on: Nov. 19, 2015
PLI Program #: 57186

Lupe Garcia is Associate General Counsel, Global Integrity & Compliance for Gap Inc. She has been with Gap Inc. for over 13 years and has led Gap Inc.'s Integrity Program since January 2006. In her current role, Lupe focuses on promoting the Company's integrity value, and enhancing the Company's legal compliance around the world. She is also on the Steering Committee for the Company's Latino Employee Resource Group. 

Prior to 2006, Lupe was a Senior Corporate Counsel at Gap Inc. focused on employment law matters, and established the Company's International Employment Law practice. She was recently appointed by Governor Jerry Brown to serve on the Board of Trustees for the California State University. Lupe is also on the Board of Directors for the Lawyers' Committee for Civil Rights of the San Francisco Bay Area, and a member of the Ethics & Compliance Officers Association, as well as the Bay Area Ethics & Compliance Association.

Before joining Gap Inc., Lupe was an associate at Lafayette and Kumagui, practicing employment law. She received her law degree from the University of San Francisco and a B.A. in Public Policy from Occidental College. Lupe lives in Alameda, California with her husband and son.

Larry is the Manager Ethics Compliance for Norfolk Southern Corporation. Norfolk Southern Corporation is one of the nation’s premier transportation companies. Its Norfolk Southern Railway Company subsidiary operates approximately 20,000 route miles in 22 states and the District of Columbia, serves every major container port in the eastern United States, and provides efficient connections to other rail carriers. Norfolk Southern operates the most extensive intermodal network in the East and is a major transporter of coal, automotive, and industrial products. Larry is responsible for the effective management of the Corporation's ethics and compliance awareness activities and oversees the investigation of hotline allegations and other allegations of fraudulent activity, conflicts of interest and similar actions.

Larry has over 30 years of investigative experience in both the public and private sector. He previously worked as a Property Crimes Detective/Polygraph Examiner with the Roanoke City Police Department in Roanoke Virginia before joining the Norfolk Southern Railroad Police Department. 

Larry holds a Bachelor of Science degree in Management from Bluefield College. He is a Certified Compliance and Ethics Professional, Certified Fraud Examiner, Certified Forensic Interviewer, and Certified Fraud Specialist.

Alex Sleightholme brings over 15 years of professional services experience with the Big 4, assisting clients with complex issues related to corporate compliance, operating model design, investigation and revenue authority disputes. Alex focuses on assisting clients with business integrity and corporate compliance needs, including bribery investigations and anti-bribery programs. His experience includes life sciences, media, telecoms and consumer products and has been gained across EY’s Tax, Advisory and Assurance practices.

As well as supporting clients in performing complex internal investigations Alex uses his experience to assist companies in identifying where risks are present, using investigation techniques to understand the business activities being carried at the lowest level, and how to best manage those risks from an operational perspective. Alex’s most recent experience is helping a global pharmaceutical company design an independent business monitoring strategy to enable the company to monitor 15 risk areas consistently across all of its global operations. Alex is also currently assisting a global pharmaceutical company respond to a Department of Justice investigation into alleged breaches of the Foreign Corrupt Practices Act, which has involved in-depth investigation in several countries to understand local business practices and individual behaviors, as well as investigation the related accounting entries. Alex has also recently been assisting a global pharmaceutical company to design a program to support commercial staff understand and identify compliance risks (including bribery and corruption) based on policies and procedures in place.

Alex has worked for EY in the UK, India and the United States and is experienced at working in diverse cultures and leading multi-jurisdictional teams working across several time zones.

His EY career has seen Alex assist companies with responding to revenue authority investigations, manage the transition to using a shared service centre, design a new operating model for a global finance function, as well as his work in assisting companies in understanding how they are exposed to compliance risks and how to manage them.

Alex has a Bachelor’s degree in Law, is a qualified Barrister, and is a member of the Association of Certified Fraud Examiners.

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.

Carl Goldberg is Vice President, Compliance & Ethics for Macy’s, Inc.  He as been with Macy’s for over 17 years and has led Macy’s Compliance & Ethics group since 2010.  In his current role, Carl focuses on promoting the Company’s Integrity Always value and enhancing legal compliance throughout the Company. 

Prior to 2010, Carl was a Senior Counsel in Macy’s legal department, focusing on operational issues, including solar, vendor and loss prevention matters.  Carl is the President of the Board of East Bay Agency for Children.

Before joining Macy’s, Carl was an associate at Bronson, Bronson & McKinnon, practicing bankruptcy law.  He received his law degree from Berkeley Law (Boalt Hall School of Law) and a B.A. in History from Colgate University.  Carl lives in Oakland, California with his wife and 2 sons.

Chad Fentress’s vision and impact in ethics and compliance has been well recognized by the ethics and compliance community. He has served as the Chief Ethics & Compliance Officer for Accenture Plc, Nokia Inc., Applied Materials and the Ethics Officer at PayPal.  His responsibilities included developing codes of conduct, conflicts of interest management, enterprise wide training and communication, data privacy compliance, trade compliance, anticorruption and antibribery, competition law, internal investigations, antifraud programs, and labor relations.

Chad has also worked beyond the enterprise to promote ethical conduct including non-governmental organizations such as the World Economic Forum’s Partnering Against Corruption Initiative and made substantial contributions to the UN Global Compact as a member of the Principle 10 Task Force where he wrote significant portions of the UN’s Guidance.

Extensive International Experience: Chad has lived and worked around the world helping multinationals strengthen their ethics programs globally, including long-term assignments in Buenos Aires, Tokyo, Sydney, London and Helsinki. He thrives in new and challenging environments where he can quickly understand the culture, business and model. 

Innovation:  Chad created the “code of conduct 3.0” which replaced a static pdf code with interactive content to engage employee.  His “cyclical training” approach rotates a set of ethics & compliance training courses over a 4-year period -- reducing total annual training time and increasing risk mitigation.  Chad combined a qualitative and quantitative approach to global risk assessments focused, combining employee survey tools that comprehensively examined key ethics and compliance risk areas and qualitative interviews of key employees to pin point compliance risks.  To ensure the cultural relevancy of global programs, he has worked extensively with the leadership of local country subsidiaries to help them identify and mitigate local country risk.   Using regular employee “culture of ethics surveys” he has identified disparities among employee groups in their perception of ethics and worked with management to improve those perceptions and mitigate compliance risk. He created Nokia’s first corporate investigations function.  Under his management, this group identified and recovered millions of Euros from internal fraudsters.  He has also developed and implemented a COSO based Fraud Risk Management program at PayPal.

Chad has served as a faculty member to international symposia dedicated to corporate governance and compliance.  The Ethisphere Institute recognized Chad as one of the top 10 Compliance Officers in 2009 for his work at Accenture.  Chad founded Novare Consulting in 2017 and provides ethics and compliance consulting services to major multinationals.

David Farrell is a Lecturer in Law at Santa Clara University Law School, where he is helping to develop an online masters degree program in corporate ethics and compliance.

David has twenty years of experience as a Vice President and Chief Ethics and Compliance Officer at Yahoo, Inc. and Sun Microsystems, Inc., where he built and led the first ethics and compliance programs for both companies.  His experience includes: advising executive management and the Board of Directors regarding business conduct and corporate compliance issues; promoting global awareness and consistent enforcement of ethics and compliance policies; establishing resources for employees to identify, report and resolve business conduct issues; managing global investigations; resolving conflicts of interest; and, working with management to coordinate global corporate compliance initiatives.

David's professional experience also includes working in a number of legal positions at Fortune 500 technology companies and serving as a U.S. Navy Lieutenant and Judge Advocate.  He has been a frequent speaker at legal education and compliance programs (including Practicing Law Institute, American Conference Institute and Compliance Week) and a media spokesperson on ethics and compliance topics (including The New York Times, The Wall Street Journal and Compliance Week).

Gina Saviola is Vice President and Deputy General Counsel, Ethics and Compliance at Jacobs, an international technical professional services firm, headquartered in Dallas.   Gina is based in Los Angeles and has over fifteen years of in-house experience managing global compliance programs.   Gina previously worked for Occidental Petroleum Corporation and Sumitomo Electric Industries.  Prior to going in-house, Gina was an attorney in the enforcement division of the Securities and Exchange Commission.  She began her career in white collar criminal defense.  Gina received her B.A. in Classical Studies from Duke University and her J.D. from the University of Virginia School of Law.

Jeremy Wilson is a Senior Vice President and the Chief Ethics Advisory Officer for Wells Fargo and Company.  In this role, he manages the team that handles team member requests and disclosures around ethics, business conduct and conflicts of interest.  He also functions as an ethics subject matter expert to the company.

Previously, Mr. Wilson was the Director of the award winning Ethics and Compliance Program at Cisco Systems.  In this capacity he oversaw the strategy and implementation of Cisco’s Ethics and Compliance Program including adherence to and enforcement of the Cisco Code of Business Conduct. Cisco was awarded the title of “Best Overall Compliance, Governance and Ethics Program” by Corporate Secretary Magazine and was placed on Ethisphere’s World’s Most Ethical companies list for seven consecutive years under his watch.

Prior to joining Cisco, Mr. Wilson served as the Director of Ethics and Compliance for Hilton Hotels Corporation in Beverly Hills, CA.  In this role he was responsible for the over-arching Ethics, Compliance and Privacy functions of the company.

Mr. Wilson began his Ethics and Compliance career at the Boeing Company in Seattle, WA as an Ethics Advisor working on both the commercial and defense contracting sides of the company.  Prior to joining the Boeing Ethics group, Mr. Wilson worked in various areas of Finance including: Revenue Management, Accounting, Estimating, Contract Management and Procurement.

For several years, Mr. Wilson sat on the board of directors for the Ethics and Compliance Officer Association (ECOA) where he served on the External and Governmental Affairs Committee, Nominating Committee and chaired the Marketing Committee.

Mr. Wilson holds a Bachelor of Science degree in International Business Management from Brigham Young University – Hawaii, a Juris Doctorate degree from Seattle University, and a Master’s degree in Dispute Resolution from Pepperdine University in Malibu, CA.

Nancy Higgins is the Vice President and Chief Ethics & Compliance Officer for Bechtel, a group of engineering, construction, and project management companies with more than a century of experience on complex projects in challenging locations around the world.  She is responsible for developing and maintaining Bechtel's global ethics and compliance program, including its international network of ethics and compliance officers. 

Prior to joining Bechtel in January 2007, Higgins was Executive Vice President of Ethics and Business Conduct for MCI, where she was brought in by the new CEO and the Board of Directors as a member of the executive leadership team and built a world class ethics and compliance program after the WorldCom scandal.

Before MCI, Higgins was Vice President of Ethics and Business Conduct at Lockheed Martin.  Prior to that, she headed the Office of Ethics and Business Conduct for The Boeing Company, where she created Boeing’s first company-wide ethics and compliance oversight program.  She had previously served in Boeing’s Law Department where she managed complex corporate litigation and advised the Board on shareholder litigation issues.  Prior to that, she practiced law at the Lane Powell firm in Seattle, Washington, and at Skadden, Arps in New York City.

Long active in the American Bar Association, Higgins has served on both the ABA Standing Committee on Professionalism and its Standing Committee on Ethics and Professional Responsibility.  She has also served in a number of leadership positions in the Litigation Section, including Litigation Council member and co-chair of the Committee on Corporate Counsel and the Ethics and Professionalism Committee.

She is a member of the Board of Directors of the Ethics and Compliance Association and a Fellow of the Ethics & Compliance Initiative.  In 2012, she served as a member of the Ethics Resource Center Independent Advisory Group on the 20th Anniversary of Federal Sentencing Guidelines for Organizations.  She was the 2014 recipient of the Carol R. Marshall Award for Innovation in Corporate Ethics.

Higgins is a past chair of the Working Group of the Defense Industry Initiative on Business Conduct and Ethics (DII), a consortium of defense contractors that subscribe to a set of principles for high standards of business ethics and conduct, and the Conference Board Global Business Conduct Council.

Higgins earned her bachelor’s degree in Russian History from Western Washington State University in Bellingham, Washington, and holds a law degree from the University of Washington in Seattle.  She completed the Advanced Management Programme at INSEAD, an international business school in Fontainebleau, France.

Pamela R. Davis is a partner in Orrick’s White Collar, Investigations, Securities Litigation & Compliance group.  Pam focuses her practice on defending companies and individuals in government investigations involving white collar and regulatory matters.  She has extensive experience in all facets of the FCPA and global investigations.

Pam has conducted numerous investigations for multinational organizations throughout the world. She is currently leading investigative teams throughout Asia, South America, South Africa and North America that require the use of Orrick's global resources in China, Hong Kong, the United Kingdom and the United States. Pam has been selected two times by the SEC and DOJ as an FCPA Monitor in matters involving a medical device company and a banking technology company.  She recently gained the unique distinction of being selected three times by the U.S. government to serve as an independent FCPA monitor when she was recently selected by the SEC as the Independent Compliance Consultant for a separate medical device company. 

In addition to her investigative practice, Pam conducts global reviews of existing compliance plans, FCPA Policies and Global Codes of Ethics, as well as due diligence associated with M&A work. She assists clients in revising existing FCPA and Global Codes of Ethics to fit today's heightened focus on anticorruption legislation. In addition to her significant work on FCPA related and global investigation matters, she also continues to represent companies and individuals in connection with a variety of other matters, including, health care fraud, antitrust offenses, securities fraud, trade secrets theft allegations, securities and export violations, mail and wire fraud, and environmental cases. Additionally, when a matter cannot, or should not be settled, she has substantial trial and courtroom experience in broad-based U.S. state and federal criminal matters, and related civil litigation, including more than 50 jury and court trials.

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.

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.

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.

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.

Ravi Inthiran leads the implementation and management of Ripple’s general compliance & ethics, privacy, and internal audit programs. This includes policy governance, training and communications, board reporting and enterprise risk management. Prior to Ripple, Ravi was Zenefits’ Chief Compliance Officer and Senior Director in the Global Compliance & Ethics department at McKesson (a Fortune-8 healthcare company).

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. 

Steve is one of the world’s leading integrity consultants. Described by the Wall Street Journal as “one of the most sought consultants to keep companies on the straight and narrow,” he has done ethics and compliance work in 51 countries for over a hundred of the world’s finest organizations. Since running an ethics think tank in Chicago in 1990, Steve has shaped the field in frequent presentations and publications for the Ethics and Compliance Association, Society for Corporate Compliance and Ethics, Conference Board, Practising Law Institute and many others.

Much of Steve’s recent work has involved assessing ethics and compliance programs and culture. Several examples of Steve’s work since starting Integrity Insight International in 2014 are summarized below: *Conducted an independent assessment of the ethics and compliance program of a Top 20 government contractor as part of an agreement with the US Department of Defense. Recommendations were deemed fair, reasonable and helpful.  *Assessed the integrity culture of a 35,000 employee professional services firm that wanted to understand employee perceptions about “Speaking Up.” Focus groups in eight countries yielded actionable insights for Compliance and Senior Leadership. *Conducted an independent audit of the ethics and compliance program for a multibillion dollar subsidiary of a Fortune 50 corporation as part of an agreement with an agency of the US Department of Homeland Security. *Served as the culture expert on the corporate monitoring team appointed by the US Department of Justice to oversee one of the 20 biggest global banks.*Assessed the ethics and compliance program of a real estate firm owned primarily by a private equity company that wanted outside recommendations on how the firm could strengthen its program without adding unnecessary friction or cost. *After being approved by the US Securities and Exchange Commission and the US *Department of Justice, conducted an independent assessment of the ethics and compliance program and culture of a Wall Street firm.  In addition to assessment and monitoring work as part of corporate agreements with the government, Steve continues to serve as a trusted, “go-to” adviser for CEOs, GCs, and Compliance Officers. - Train Boards of Directors and leadership teams in an engaging, entertaining way *focused on the roles and responsibilities of participants.  - Conduct risk, program and culture assessments to help Ethics & Compliance officers, leadership teams, and Boards allocate resources appropriately.

Steve founded Ethical Leadership Group in 1993, sold it to Navex Global in 2009, and founded III in 2014.  He received his ethics training in the real world of business and at Harvard University’s Divinity School, where he received a Master of Theological Studies degree. He has his MBA and BA from University of Chicago, and studied international organizational development in the Graduate Business School at Katholieke University Leuven, Belgium.          

David Greenberg works at the C-Suite and board level on governance, culture and leadership as well as on issues and strategy on ethics and compliance, corporate social responsibility and public affairs. He also writes and speaks on behalf of LRN on how our philosophy and solutions can help companies and organizations achieve their purpose through values-based self-governance.

Greenberg joined LRN from Altria Group, Inc., where his tenure of more than two decades culminated in the role of Senior Vice President and Chief Compliance Officer, heading Altria's enterprise-wide efforts on compliance and integrity as one of only five senior vice presidents of the parent corporation. Prior to this, he held numerous senior positions at Altria, and its operating unit Philip Morris International, in the United States, Europe and globally, including responsibility for environment, social responsibility, government affairs and communications.

Greenberg also was a partner with the law firm of Arnold & Porter; served as Legislative Director and General Counsel for the Consumer Federation of America; and was a legislative representative, organizer and writer for Ralph Nader. Greenberg has testified before the U.S. Congress, the European Union, the Israeli Knesset and other governmental bodies over two dozen times and has appeared on ABC Nightline, the CBS Morning News, BBC Morning, and the PBS News Hour, and has spoken at leading events for CEOs and boards.

Greenberg received a J.D./M.B.A. from the University of Chicago Law School/Graduate School of Business. He also attended Williams College and was elected to Phi Beta Kappa.

Leonard Shen is SVP-Chief Compliance Officer for Visa, Inc., the top payment network in the world. Prior to joining Visa in October 2014, he was CCO for PayPal, and before then, CCO for American Express from 2007-2010, and CCO for GE Commercial Finance from 2003-2007.

Before entering the corporate compliance field, Leonard spent 18 years in environmental law, including as a prosecutor at the US Justice Department, private law practice, the U.S. Environmental Protection Agency, the U.S. Senate Environment and Public Works Committee, and at GE.

Leonard is a graduate of Harvard College and Harvard Law School, where he was an editor of the law review. He is married with three daughters and enjoys hiking, yoga and tai chi.

Grace is a seasoned Ayurveda, yoga, meditation and mindfulness practitioner with over 15 years of teaching experience in corporate, academic and public settings.

She is a Certified Ayurveda Specialist (C.A.S.) and holds yoga certifications through Whole Birth® Prenatal Yoga and Support, the White Lotus Foundation and Kundalini Research Institute (KRI).  She is on faculty for the Yoga Teacher Training program at MindBody Zone in Fremont, CA and the Prenatal Kriya Yoga Teacher Training.

A nature lover, Grace leads yoga, meditation and nature retreats for individuals and families in the Bay Area. She most enjoys sharing the heart-opening wisdom of Ayurveda, yoga and mindfulness to help others awaken to the radiant health, harmony and joy within.