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Corporate Compliance and Ethics Institute 2015

Speaker(s): Adam Siegel, Benjamin Gruenstein, Debra M. Torres, Hon. Katharine H. Parker, Jack Holleran, Jeffrey M. Kaplan, Joel Katz, Joseph E. Murphy, Lisa Stewart Hughes, Odell Guyton, Palmina M. Fava, Paul E. McGreal, Ravi Inthiran, Rebecca Walker, Robert D. Frisbee
Recorded on: Jun. 1, 2015
PLI Program #: 57827

Debra Torres has been Senior Vice President, Chief Compliance & Ethics Officer at PepsiCo, Inc., since May 2014.  Before joining PepsiCo, Debra spent over twenty eight years at the law firm of Fried Frank Harris Shriver & Jacobson LLP, twenty-one of them as a partner in the litigation department. At Fried Frank, she specialized in securities and shareholder litigation, internal investigations and government enforcement matters. In 2009, she joined Kalorama Partners PLLC, a Washington, D.C.-based legal services and consulting firm established by her ex-partner Harvey Pitt, a former Chairman of the Securities and Exchange Commission, as Managing Director of Kalorama’s New York office. At Kalorama, in addition to working on a number of internal investigations, Debra focused on compliance reviews and consulting.

Debra has a J.D. from Yale Law School and a B.A. from Yale University. She is a member of the Board of Directors of LatinoJustice PRLDEF, a civil rights organization advocating on behalf of the constitutional and legal rights of Latinos in the United States, and a past member of the boards of the Legal Aid Society and the Jewish Child Care Association.

Adam is a partner based in our New York office and the head of our US dispute resolution practice as well as co-head of our global investigations practice. He represents clients facing government investigations and related civil litigation. Clients in a broad range of industries rely on him to defend them in investigations conducted by the US Department of Justice (DOJ), the Securities and Exchange Commission (SEC) and the State Attorneys General in matters involving alleged violations of the Foreign Corrupt Practices Act, insider trading, tax fraud and accounting fraud. He also conducts internal investigations on behalf of clients in a wide range of industries.

Adam works regularly with other firm lawyers around the world, defending multijurisdictional investigations, developing compliance and training programs tailored to the global regulatory regimes faced by clients, and conducting due diligence regarding bribery and other risks in corporate transactions.

He has been recognized by Chambers, The Legal 500 and Benchmark Litigation, among other leading publications. Prior to joining Freshfields, Adam was an Assistant US Attorney in the Criminal Division of the US Attorney’s Office for the Southern District of New York. There he served as Deputy Chief and Chief Appellate Attorney.

Adam received his JD, magna cum laude, from Harvard Law School and his AB, magna cum laude, from Harvard University. He is admitted to practice in the State of New York.

Adam’s recent matters include:

  • conducting internal investigations regarding a variety of allegations in approximately 10 countries in Asia, Latin America, Africa and the Middle East for a multinational energy company;
  • representing a Swiss financial institution in extended discussions with the DOJ and other regulators concerning its tax compliance;
  • representing a global engineering company in internal reviews of corruption allegations and in discussions with multilateral development banks;
  • defending a multinational pharmaceutical company in an inquiry conducted by the DOJ and SEC into relationships with officials in countries in Europe, Africa, Asia and Latin America;
  • conducting an internal investigation for a multinational manufacturing company involving allegations concerning its sales agents throughout the Middle East; and
  • defending the European affiliate of a Big Four accounting firm in an investigation by the SEC and the Public Company Accounting Oversight Board regarding the audit of a client.

Benjamin Gruenstein is a partner in Cravath’s Litigation Department and a member of the Firm’s Investigations and White Collar Criminal Defense practice.  His  practice focuses on the representation of U.S. and multinational companies and their senior executives in government and internal corporate investigations in such areas as the Foreign Corrupt Practices Act (“FCPA”), healthcare fraud, insider trading, criminal antitrust, accounting fraud and trade sanctions and accompanying civil litigation.  Mr. Gruenstein has handled both domestic and cross-border investigations, including in Latin America, Asia and Europe.

Prior to joining Cravath, Mr. Gruenstein served as an Assistant U.S. Attorney in the Criminal Division of the U.S. Attorney’s Office for the Southern District of New York from 2002 to 2008.  He returned to Cravath in 2008, and became a partner in 2012.

Mr. Gruenstein is a fellow of the American Bar Foundation.  Mr. Gruenstein has been recognized for his white collar criminal defense work by Benchmark Litigation (2016-2020) and The Best Lawyers in America (2016-2020).  He has also been recognized by The Legal 500 United States for white collar criminal defense work (2016-2019), general commercial disputes (2019), securities litigation and related regulatory enforcement matters (2015-2017) and for his experience in the media and entertainment industry (2017-2018).  From 2013 through 2018, Mr. Gruenstein was selected by Lawdragon as one of “500 Leading Lawyers in America.”  He and his colleagues earned the Firm a top tier ranking for Criminal Defense: White Collar in the U.S. News Best Lawyers “Best Law Firms” survey in 2018, as well as recognition in the investigations and criminal defense categories of both Chambers USA (2015-2019) and Legal 500 US (2016-2019) and the FCPA category of Chambers USA (2018-2019).  In 2014 and 2015, Mr. Gruenstein was named one of Ethisphere Institute’s “Attorneys Who Matter” and in 2013, he was recognized as one of five Law360 “Rising Stars” in the nation in the White Collar category.

Mr. Gruenstein received an A.B. summa cum laude in Philosophy and Mathematics from Harvard College in 1996, where he was elected to Phi Beta Kappa, and a J.D. magna cum laude from Harvard Law School in 1999, where he was an Editor of the Law Review.  After graduating from law school, Mr. Gruenstein clerked for the Honorable Stephen F. Williams of the U.S. Court of Appeals for the D.C. Circuit and for the Honorable David H. Souter of the U.S. Supreme Court.  

Bob Frisbee serves as the Ethics and Compliance Director for Southern Company.  He is responsible for the Code of Ethics, Corporate Concerns, Personnel Risk Assessment, Data Loss Prevention and the overall compliance program structure across Southern Company. Bob began his career in 1982 as a plant chemist in Generation at Georgia Power and has held other positions at Georgia Power and Southern Company. Bob has earned two bachelor degrees, one in biology from the University of West Georgia and the other in accounting from Kennesaw State University. He is a certified public accountant in Georgia, a certified environmental, safety and health auditor and a certified compliance and ethics professional.

Bob is a member of the Society for Corporate Compliance & Ethics, the Atlanta Compliance and Ethics Roundtable, the Ethics and Compliance Officer Association, and serves on the Board of Governors at Georgia State University’s Center for Ethics and Corporate Responsibility. 

Jack Holleran currently serves as Managing Director, Compliance at Moody’s Corporation, based in New York City.  In this role, Jack serves as the Chief Compliance Officer for Moody’s Analytics, a global developer and provider of products, solutions and services that help financial institutions manage risk.  Moody’s Analytics is part of Moody’s Corporation and an affiliate of Moody’s Investors Service, the credit rating agency, with more than $1.7 billion in revenue in 2018.  Jack is responsible for the design, implementation and effectiveness of the Moody’s Analytics compliance program.  Jack also serves as the Chief Compliance Officer of Moody’s Shared Services and as the principal architect of Moody’s anti-bribery and anti-corruption program.

Prior to joining Moody’s, Jack served as Senior Compliance Officer at Marsh & McLennan Companies, Inc., where he worked with MMC and its operating companies to lead compliance and enterprise risk assessments, to drive integration of compliance and ERM and to lead process improvement opportunities arising from risk assessments.  Prior to joining MMC, Jack was a principal with EY (Ernst & Young) in Washington, D.C., where he led the firm’s Corporate Compliance Advisory Services practice.  In that role, he advised clients on compliance risk assessments and compliance program design, implementation, assessment and improvement.  Prior to joining EY, Jack served as Senior Vice President, Compliance and Brand Integrity and Chief Compliance Officer at Philip Morris USA.  In that role, he served on the executive management team and was the principal architect of the company’s compliance and anti-counterfeiting programs.  Jack began his career as a trial lawyer with Hunton & Williams in Richmond, Virginia.

Jack is a graduate of Dartmouth College and the Washington & Lee University School of Law.  He is a frequent speaker and author on ethics and compliance-related topics, including Practising Law Institute, Compliance Week, the Society of Corporate Compliance and Ethics, the Conference Board and Metropolitan Corporate Counsel.

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.

Joel has worked in corporate legal and compliance roles for the past 20 years.  He has significant experience building structures, programs and training that promote cultures of integrity and compliance and drive high levels of employee engagement.

Joel most recently served as the Chief Integrity and Compliance Officer for Resideo Technologies, Inc., (NYSE – “REZI”) a publicly traded global homes and distribution business with $4.8B in revenue and 14,000 employees that spun-off from Honeywell in 2018.  At Resideo Joel developed a comprehensive compliance plan for the first 24 months post-spin that included a robust risk assessment, a new Code of Conduct, a new investigation process that drove greater accountability to the business while reducing investigation cycle times and a training and communications plan to establish the correct “tone at the top” and increase employee engagement on integrity and compliance issues.

Previously, Joel held several leadership positions with CA, Inc. (NASDAQ – “CA”), a $4.5B publicly traded global provider of business software and professional services that was acquired by Broadcom, Inc. (NASDAQ - “AVGO”) in 2018.  Joel most recently served as CA’s Chief Ethics and Compliance Officer from 2011-2018 and built the Compliance Program that directly contributed to CA being named one of the “World’s Most Ethical Companies” by the Ethisphere Institute for four consecutive years.  Earlier in his tenure with CA, Joel played a critical role in CA’s successful completion of a Deferred Prosecution Agreement with the federal government stemming from a corporate accounting scandal.  Joel worked closely with CA’s court-appointed independent monitor throughout the DPA, including traveling around the world to evaluate compliance risk and conduct “tone at the top” interviews of company leadership.

Joel began his career with Williams Mullen L.L.P. (formerly Maupin Taylor & Ellis, P.A.), a full-service law firm with practice areas across diverse industries. He devoted his practice to representing management in labor and employment-related legal issues.

Joel earned his Juris Doctor with distinction from Hofstra University School of Law and his Bachelor’s degree from the University of Michigan. He serves as a Member of the Board of Directors (2014 to present) of the Ethics and Compliance Association (ECA); is a Kallman Executive Fellow of the W. Michael Hoffman Center for Business Ethics at Bentley University and is a frequent speaker and author on issues related to business ethics, corporate compliance and law department leadership. 

Joel was selected as a 2016 “Top Mind” by Compliance Week Magazine - “some of the brightest and most influential thought leaders in the world of governance, risk, and compliance” and was recognized as a top Ethics & Compliance Officer by the Ethisphere Institute in 2013.

Judge Parker was sworn into office on November 4, 2016. She received a B.A. degree, cum laude, from Duke University in 1989. In 1992, she received her J.D., cum laude, from Fordham University School of Law, where she was elected to the Order of the Coif. She was a Notes & Articles Editor for the Fordham Law Review.

From November 2000 through October 2016 she was a partner at Proskauer Rose LLP where she practiced labor and employment law and chaired several practice groups including Employment and Law Counseling and Training and Government Regulatory Relations and Affirmative Action. She was associated with the Proskauer firm from October 1993 through October 2000 as an associate.  While at Proskauer, she had an active litigation career in cases involving the full gamut of federal, state and local employment laws. She also litigated cases involving fair housing, civil rights, non-compete, contract and employee benefits disputes.

While at Proskauer, Katharine was elected to be a Fellow of The College of Labor and Employment Lawyers and consistently honored in various listings such as Best Lawyers in America and New York Super Lawyers.

Judge Parker clerked for the Honorable Warren W. Eginton in the U.S. District Court for the District of Connecticut prior to joining Proskauer.

Judge Parker has been actively involved with the NYC Bar Association during her career, and has chaired both the Disability Law and Employment Committees.  Judge Parker is also involved in pro bono and charitable causes, including the Michael J. Fox Foundation and Girl Be Heard.  She was a recipient of the Fairy Godmother Award from Girl Be Heard and the Jeremy Epstein Award for Pro Bono Service from the NYC Bar Association.

Mr. Odell Guyton, JD, CCEP, CCEP-I, is the Corporate Vice President, Head of Global Compliance for Jabil Circuit, Inc., St. Petersburg, Florida, USA, a diversified manufacturing services company with over 200,000 employees in 33 countries. Mr. Guyton is a Society of Corporate Compliance and Ethics (SCCE) Co-Founder and Co-Chair.  He is a recognized industry leader in designing, implementing, and managing effective corporate compliance programs for multi-national organizations. He has a significant track record of accomplishment in the legal field and the domestic (U.S.) and international compliance and ethics field.

He is a frequent lecturer on the implementation and administration of anti-corruption and anti-bribery compliance measures focused on U.S. Foreign Corrupt Practices (FCPA) and the U.K. Anti-Bribery Act. He serves on several United Nations workshops related to fighting corruption including the “UN Global Compact Guide on Fighting Corruption in Sport Sponsorship and Sport Related Hospitality” and “The UNODC Anti-Corruption Ethics and Compliance Handbook for Business.”  He is an expert consultant for the Humboldt-Viadrina, School of Governance, Berlin Germany in preparing their “Guide for Motivating Business to Counter Corruption-Using Sanctions and Incentives to Change Business Behavior”. He is a lecturer for the International Anti-Corruption Academy, Laxenburg, Austria.

Mr. Guyton is highly experienced in corporate internal investigation, complex litigation, criminal defense, internal controls, and preventative law and in the design and implementation of compliance programs. He has direct experience in technology, healthcare and university compliance. Mr. Guyton is licensed to practice by the Supreme Court of Pennsylvania Bar, the Washington State Bar Association, the U.S. District Courts, and U.S. 3rd. Circuit Ct of Appeals licenses. He is a Certified Compliance and Ethics Professional (CCEP, CCEP-I). He recently retired as Assistant General Counsel and Director of Compliance for the Microsoft Corporation. Prior to his appointment with Microsoft Corporation he served as the Corporate Compliance Officer for the University of Pennsylvania and University of Pennsylvania Health System. Previous to employment at the University of Pennsylvania, Mr. Guyton was engaged in the private practice of law. Mr. Guyton has served as a prosecutor in the United States Attorney’s Office and the Philadelphia District Attorney’s Office. He has served on several governing boards. He serves as Special Advisor on Compliance to the University of California Board of Regents and has been named as one of the “100 Most Influential Persons in Business Ethics” (Ethisphere Institute (2008)); Attorneys Who Matter (Ethisphere Magazine (2009; 2010, 2011). He also holds a Martindale-Hubbell “AV” (Preeminent) Highest Peer Review Rating. He studied bio-ethics at the University Of Pennsylvania School Of Medicine and received his Juris Doctor degree from the American University, Washington College of Law and earned his Bachelor of Arts degree from Moravian College, Bethlehem, Pennsylvania.

Palmina Fava is a partner in the New York office of Vinson & Elkins, LLP, specializing in internal and government investigations, white collar criminal defense, and corporate governance counseling.

Palmina regularly represents companies in matters before the United States Department of Justice (DOJ), the Securities and Exchange Commission (SEC), other federal and state agencies, and international regulatory bodies related to the Foreign Corrupt Practices Act (FCPA), international anti-corruption, anti-money laundering and anti-bribery laws, accounting irregularities, bid rigging and unfair trade practices, off-label pharmaceutical marketing, misappropriation of trade secrets, fraud, cybersecurity, and data privacy.

Additionally, Palmina designs and implements practical and comprehensive compliance programs and internal controls tailored to a company’s particular risk profile.  She also conducts third party and M&A due diligence, develops and provides training, and drafts compliance reps and warranties.

Palmina graduated cum laude from Georgetown University in 1994 and received her J.D. with honors from Fordham University School of Law in 1997. She is President of the Fordham Law Alumni Association and a board member of the Kidney & Urology Foundation of America and of New Classrooms. 

Palmina is fluent in Italian and proficient in Spanish and Portuguese.

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.

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 nearly 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 Institute in New York and their annual Advanced Compliance and Ethics Workshop in San Francisco.  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. 

Endeavor Group Holdings is comprised of a diverse group of media and entertainment businesses including the William Morris Talent Agency, IMG Models, Ultimate Fighting Championship, and the Miss Universe Organization. The company has revenues exceeding $2B annually and is headquartered in Beverly Hills, New York and London. Ms. Stewart Hughes is responsible for the overall direction, design and implementation of Endeavor’s Global Ethics & Compliance Program.  Prior to joining Endeavor in 2018, she served as Deputy Chief Compliance Officer at NBCUniversal and as a commercial litigator at Simpson Thacher & Bartlett in New York City and Hogan & Hartson in Washington, DC. 

Ms. Stewart Hughes is an author, speaker and expert on building and implementing effective compliance programs, as well as a trainer and advocate for gender equity, harassment prevention, and diversity and inclusion.  She has published, lectured and led workshops for organizations including the Practicing Law Institute, the Society of Corporate Compliance and Ethics, and the Business Roundtable on Ethics.  She serves on the Compliance Committee of the New York City Bar Association, and has previously served on the Boards of Directors for the Women of Tomorrow Mentor & Scholarship Program and the Embrace Music Foundation.


Ms. Stwart Hughes received her J.D., from Harvard Law School and is a graduate of Yale University, where she received her cum laude BA in Political Science.  She enjoys writing, yoga, boozy cupcakes, vegan cooking and travel.  She is a lover of chocolate, wine, bacon, and golden retrievers (in that order).


For over 40 years, Joe Murphy, CCEP, has been a tireless champion of compliance and ethics in organizations and has done compliance work on six continents. Joe has published over 100 articles and given over 200 presentations in 17 countries.  Joe is author of 501 Ideas for Your Compliance & Ethics Program and A Compliance & Ethics Program on a Dollar a Day. He is a Certified Compliance & Ethics Professional and Editor of the SCCE publication, Compliance & Ethics Professional. Joe was named one of The National Law Journal’s 50 Governance, Risk and Compliance Trailblazers and Pioneers 2014 and was a winner of SCCE’s Compliance & Ethics Award . He is a member of the Pennsylvania and New Jersey bars.

Ravi Inthiran leads the implementation and management of Zenefits’ compliance & ethics program, product (HR saas platform, benefits, payroll and other financial products) compliance, regulatory change management, and internal audit programs. This includes enterprise policy governance, compliance training and communications, investigations, board reporting and enterprise risk management. As Zenefits’ Chief Compliance Officer, Ravi reports to the General Counsel and the Zenefits’ Board of Directors. Prior to Zenefits, Ravi was Senior Director in the Global Compliance & Ethics department at McKesson (a Fortune-8 healthcare company), responsible for a wide swathe of McKesson’s U.S. compliance program, and spent 13 years at Deloitte, working with numerous clients to assess and create compliance programs centered on privacy, data security, and overall control environments.