Microsoft Talks Ethics and Compliance Shop

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To read or scan the full interview, check out the transcription below: 


Alan: My name is Alan Gibson. I am an Assistant General Counsel in the Office of Legal Compliance at Microsoft.

Interviewer: Tell us a little bit about your company, number of employees, etc.

Alan: We are truly a global business, and I believe we operate in somewhere around 200 countries.

Interviewer: Great! And back to our earlier conversation about the ethical shift in the workplace and moving from compliance to more about employee values and ethics. Either you can say it from the perspective of what you’re seeing or where you think it should go.

Alan: It’s been an interesting journey for us as we look at how to switch from a rules-based code of conduct or a rules-based strictly company to a values-based company. It was a journey we started two or three years ago. For us, we started with our standards-of-business conduct, the equivalent of our code of conduct. What we’re focused on now isn’t, “Do this. Do not do that.” It’s more about asking how do we equip people to make the right decisions for the company, for themselves, and for their community. And that’s what we really focus on as we talk about having a value-based code. As we look at having the value base code across our culture, that is what we are really equipping employees to use when they come across a business decision or an ethical decision, to pause, think and ask.

Ethics and Compliance at Microsoft 

Interviewer: Tell us about your program and what the make-up of the team is.

Alan: At Microsoft, the Office of Legal Compliance consists of somewhere around two dozen full-time employees spread out in departments across the world. At headquarters, we’re really divided into two teams, one of which is focused on compliance investigations. And so that’s a team that’s made up of attorneys that are focused on investigating allegations of misconduct and we also have a forensics team. The forensics team is just like it sounds where it’s CSI type work in terms of going into people’s computers or recovering information that allows us to conduct investigations. Then there is the programs team within the Office of Legal Compliance, and I sit on that team. What we’re focused on is really implementing this ethical culture or this values-based culture. Within our team, we’re focused on the standards-of-business conduct, training, our communications plan, and then there’s the piece of work that I’m responsible for, which is the compliance analytics program. I’m tasked with designing and implementing an early warning and monitoring system for a defined set of compliance risks using data analytics.

Interviewer: How important is the role in technology in this shift from a “check the box on compliance,” to focusing more on ethics and values?

Alan: As far as the role of technology and data in this shift from being rules-based to more of a values-based, the way that we use our data is really as this early warning and monitoring system. What we’re trying to do is get the pulse of our employees to help them make the right decision. And if we see risk being created by their behavior, we want manage that risk, reduce the risk, or mitigate the risk instead of catching them after the fact. We’re not trying to necessarily detect and monitor for misconduct, we want to equip them so that we can prevent the misconduct. I don’t know the statistics off the top of my head, but there’s a lot of unintentional misconduct. And we just want to equip people to make the right decisions, and we think data is one of those tools that will allow us to do that.

How Software and Convercent is Helping You

Interviewer: Great. Can you speak about the Convercent Ethic Cloud platform and tie it to that, to data, and how you’re leveraging our platform?

Alan: The interesting part about Convercent’s cloud-based solution for us is you start to see the possibilities once you start to combine disparate data sets. It is going to allow us to create these, what I call, actionable insights in ways we just haven’t had the ability to do it before. We are excited to see where Convercent is going and where the industry is going as we start to aggregate all this different data and we create the ability to combine trends, patterns, and relationships and the result is actionable insights.

Interviewer: Is there anything else around benefits?

Alan: One of the benefits I see that I don’t think Microsoft has taken advantage of, and I don’t know if other clients have taken advantage of, is the ability to use the data and visualize it in a way that allows you to more effectively communicate with, for instance, our audit committee. The sort of questions we get asked could be we see you have 10 more of a certain type of case or investigation. “Can you help us see the forest through the trees? What should I be taking away from this data?” And I think there’s going to be an ability to create these visualizations that’s going to tell the story of what’s going on in your compliance program. Is it getting better or is it getting worse and how do you know it? And you must be able to package that sort of information or data in a way that it can be consumed by these executives. I think that’s a huge opportunity.

I think there’s going to be an ability to create these visualizations that’s going to tell the story of what’s going on in your compliance program.

Interviewer: Does Convercent support your company’s overall ethical journey, and if so, how?

Alan: Yeah it is. I think the implementation of the solution starts to equip employees to know the, “how.” And what I mean by that is that it allows people to interact or share their concerns, raise their issues, and ask their questions more effectively.

Interviewer: Employee engagement and employee involvement in the problem and solution is a big part of what Convercent is doing.

Alan: I’m excited to hear about where Convercent is headed with their solutions, primarily because they’re thinking about some of these “how” questions. Or answering certain compliance questions in ways that I don’t think other companies are necessarily thinking about at this point in time. So, I am excited to learn about products such as the interactive code of conduct. I haven’t heard that of other providers, and I think it’s an exciting opportunity.

Moving Forward

Interviewer: All right, last question. This is forward-looking and you may have a comment on it or not, but looking ahead, what impact do you think building more ethical companies will have, beyond the impact on the businesses themselves? Convercent’s vision is to drive ethics to the center of business for a better world and we’re curious if companies have a similar vision. For example, communities, cultures, the economy. Do you see creating more ethical companies as having an impact beyond Microsoft?

Alan: A piece of it is our business practices, but we live it on a day-to-day basis in terms of our involvement in the communities, our philanthropic programs, and the level of engagement with our employees. I believe employees have now given over $100 million through our giving campaign. And for us, I don’t think it’s just words on a sheet of paper. We’re actually living those values on a day-to-day basis. We see the merits for the company, yes. We also think it’s the right thing to do for ourselves and our communities.