Compliance &Ethics - Society of Corporate Compliance and Ethics

FeatureMueller places on compliance programs. AsPatrick Kelley noted, “He recognizes you asthe first line of defense.” The program beganwith Kelley outlining the mission of the FBI,which places prevention of terrorism as itsfirst priority.He also shared the Bureau’s motto—Fidelity, Bravery, Integrity—noting thatintegrity is very much at the core of theBureau’s compliance program. It is even oneof the organization’s core values, he explained.Director Mueller said, “In fact, integrity is thevalue that binds together the very fabric of ourinstitutional identity. It defines us and whatwe stand for; it is how we operate and how wemeasure our success. In short, integrity is thetouchstone for everything we do.”All new Special Agents of the FBI receiveeight hours of ethics training, versus thestandard of just one hour for most federalemployees. In addition, immediately prior tobeing sworn in for their positions, every FBIemployee is shown a video that highlightsthe Bureau’s core values. The inspiring productionfeatures FBI employees who faceddifficult decisions in which they were guidedby the core values.“We thought that using real FBI personnelto tell real FBI stories to illustrate each ofthe core values would be the best way to reachboth experienced and new employees, and toshow that the values really are more than justwords,” said Kelley.The compliance and ethics programdoesn’t stop with the video, though. Thereis a permanent office with a total staff of 17people. In addition, compliance managementcommittees, organized along branch or functionallines, meet each quarter, and there is aformal meeting every four months with theFBI director and the top executives to reviewthe program and the risk areas.Attendees left favorably impressed by theFBI’s efforts. “I left with a deeper appreciationof the FBI organization. There were manyvaluable lessons to be taken from the program,but one that left a lasting impressionwas the FBI core values. The FBI valuesare ingrained throughout their businessorganization, and it is a message that is leveragedfrom the top down to all employees.Everyone is expected to be a leader!” saidTerri Lee, Corporate Responsibility Leader ofthe Electric Power Research Institute.The program for the meeting wasn’tsolely about the FBI’s compliance and ethicsprogram. It contained a number of sessionsdesigned to both enhance the Compliancecommunity’s understanding of the FBI and ofcompliance risks that the private sector faces.Bryan Smith of the Economic Crimes Unitwarned the attendees of an uptick in securitiesand commodities fraud, particularly aroundinsider trading. He went on to explain thatthe FBI prioritizes these cases based on factorssuch as systemic risk to the US financialmarket and public confidence in the US financialsystem, as well as the number of victims.He also provided strong ammunition to thoseadvocating for self-reporting of incidents. Heassured the attendees that the companies thatself report and cooperate fare far better thanthose that do not.Madeline Payne, an Intelligence Analystwith the Economic Espionage Unit, followedBryan Smith’s presentation. Her focus, andthat of her unit, is protecting trade secretsfrom misappropriation. It’s a significant problem,especially among engineers, because somany trade secrets reside in their heads.It’s also a problem with two fronts for companiesto consider. While most might focus onthe loss of a trade secret to a competitor, thereis another grave challenge: the transfer of proprietarydata to foreign governments. Thosecommitting this type of crime are also significantflight risks, because they are often nationalsof the country that they are stealing data for.Compliance & Ethics Professional May/June 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 15