February 2

Everything Ethics Interviews Michael Clark


I interview Michael Clarke, Chief Global Compliance Officer of ConvaTec, about managing the compliance function through the pandemic.

J Kevin Foster: What changes and issues are coming up, and maybe, what you're doing as far as monitoring what's going on with your employees. How has it changed since the pandemic?

Michael Clarke: I mean everyone being virtual, and we are always having discussions about to what extent our sales colleagues can go back into the field.  That's being discussed business unit by business unit, case by case. But for the most part, we're trying to remain as virtual as possible.  With that being the case, we're always thinking about how, if everyone's virtual, what sort of things can we manage the sales forces' promotional teams.

In terms of making sure they don't take excessive risk because I think when everyone's home by their computer and they're a bit more relaxed, and they may say things or do things, even though they're not physically with someone. They may say something or do things that are not entirely consistent in our practices, so we need to make sure we get in front of them or educate them or talk to them.

So there's a lot more virtual education we have to do.  So many meetings on whether we streamline specific processes, but keep adherence to our policies, those are probably the biggest things that we've had to address in the corporate environment.

J Kevin Foster: Are the individual supervisors pretty much taken that role as far as monitoring, or is there any other way you're doing it?

Michael Clarke: Yeah, they do it.  It is all virtual so having virtual promotional meetings.  Let's say I'm selling to you. You're a doctor, and I'm the sales rep, and we're having a virtual meeting rather than in the office.

My manager would dial on three of us on a zoom call or team call, and we do the same thing in the compliance context. We haven't done monitoring like we do not feel right along; we mostly do it for big meetings like just the education sessions and training sessions.  We have done it for a few add boards advisory boards.

J Kevin Foster: So the educational aspect is that more based on your regular ethics training programs or are you creating any new programs?

Michael Clarke: It's a bit of both.  Since I'm new, I had been updating our training anyway because we hadn't really refreshed it.  ,  You need to rethink these things all the time.  We have tried to jazz up our training a bit. Everything that we're delivering, whether it's national sales meetings we had, we squeezed in a couple before Covid.  And now we're doing a lot more town halls, more localized regional conferences. So we have jazzed up the training for all of those large gatherings. I'm redoing a deck for some distributor training.  So we're making punching up the content, making it a little more interesting. Reducing the text but still conveying the same message.  Eventually we want to move more towards better technology solutions, whether for internal sales teams or any other.  We train everybody so whether it's employee training, sales field training, or third-party distributor training.

We're trying to use more technology solutions to deliver content now because it's all online. So I want to try and do it in a more interesting way more engaging way right

J Kevin Foster:  Your title is global chief compliance officer.  Do you have the ethics function as well?

Michael Clarke: Yeah, I mean it's ethics and compliance.  That's the way I've been thinking about this.  For the last ten years,   I've always had ethics. I started off as an ethics officer at a healthcare company and then started moving up to become either our regional or global compliance officer.

The ethics component is critical because that's how you determine what your culture will be, what sort of ethical compass you have in making business decisions. So you've been on the global chief compliance officer when I referred to the program. It's an ethics and compliance program.  It's more than just what the rules say or what the regulations are the guidance issue.   Let's empower you to make sound ethical business decisions.

We will try to give you the tools to do that. But we also are available for any questions or concerns you have if you're thinking you're coming to either a fork in the road, whether it's two choices, have three options. We're here to help you, give you the tools to help you make those decisions.

Compliance, I think, is easy. You push out the rules and adhere to them. But then there's always going to be some slippage

J Kevin Foster: So when you're talking about ethics, you're talking about values-based ethics. You have to communicate that in all those different languages and incorporate it into the culture. So you got to get everybody speaking the same vocabulary.

Michael Clarke: Absolutely.

J Kevin Foster: And then the training, gotta be able to reinforce that language. Then, all the leaders have to be in place to make sure that they're reinforcing with all their employees and obviously leadership changes all the time, you have a new generation of leaders come up all the time.

And sales or wherever it's it's relevant, and those people who are responsible for maintaining that culture, making sure all their folks who they're hired can speak the same language and be able to understand where the corporate culture is aimed at

Michael Clarke: Yeah, absolutely, that is important. You've got to have leaders at both the top, whether it's CEO level or divisional leaders, business unit leaders, functional leaders, middle-level managers who speak the right language, or saying conveying similar consistent messaging.  Then people who are not in the management role, who are in the field or on the line, hear those things over and over again and realize this is something that is baked into the organization. I should teach myself going into how I do my job, whatever it is.


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