Compliance &Ethics - Society of Corporate Compliance and Ethics

with the support of the board members, whohave also always believed in the necessity ofthis department.AT: How standard is it for companiesin Guatemala to establish a Compliancedepartment?CI: We are one of the leading Guatemalancorporations. This is a new trend, seen todayas an actual necessity. Cementos Progresohas been recognized and given awards byCentrarse, which is a local entity that promotesthe social responsibility of companies.AT: How is the compliance team structured?CI: The compliance officer reports to theAudit Committee. Here we call it the Riskand Compliance Committee. There is a vicepresident who is responsible for Compliance,Legal and Risk (audit). The compliance officerreports organizationally to him.AT: What’s your background, and how didyou become a member of the compliance team?CI: I have twenty-three years of experience,mainly in banking. I was treasurer of the secondlargest bank in Guatemala during early 1990s,then I worked almost nine years for Citibank asCountry Treasurer, and then I was the FinancialInstitutions and Public Sector Head.While I worked for Citibank, we focusedon training banks, financial companies, andthe government with topics like anti-moneylaundering, know-your-customer policies,managing regulatory issues, etc. Due to mybackground, I started as an advisor to the Riskand Compliance Committee, becoming theCorporate Compliance Officer.AT: What is the outline of your program?In the U.S., companies tend to follow theFederal Sentencing Guidelines, of course.What did you use?CI: Basically, my role as a CorporateCompliance Officer is to establish the mechanismsof control and application of the code ofethics and conduct. And I effectively managethe mechanisms to notify us of good or badconduct. The hotline, emails, suggestion boxes,and notifications are presented directly to me.I also work to create a culture of integrityand doing the right thing. This includes establishingprocedures and controls to identifyand manage conflicts of interests. I also monitorthat the company complies with the lawsand regulations, supported by areas such asInternal Audit and Legal.AT: What are some of the key compliancechallenges that Grupo Progreso faces?CI: Trying our best, through our people,to help change a negative view of complianceinto a winning culture and a winningorganizational compliance culture! It is achallenging subject, since locally you need toconvince the board members that implementinga code of ethics and all of the compliancestructure will benefit the company, and it’snot only an extra bureaucratic process withinthe company.AT: Are these challenges typical for yourindustry, or are they common for other businessesin Guatemala?CI: They are common for all businesses inGuatemala.AT: What role does the Guatemalan governmentplay in encouraging compliance programs?CI: They have been proactive by starting toimplement the role of the compliance officerin the financial system with strict anti-moneylaundering controls, and all internationalrequirements, such as the antiterrorist laws.The government—the Superintendent of TaxAdministration, for example—has enforcedand strengthened regulatory issues and controlssignificantly. ✵Adam Turteltaub is Vice President of Membership for SCCE. Hecan be contacted at adam.turteltaub@corporatecompliance.org.Christie Ippisch can be contacted at cippisch@hotmail.com.Compliance & Ethics Professional May/June 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 53