ON Semiconductor: Technology’s Role in Ethics & Compliance

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

Introduction & Company Background

Mark: My name is Mark Rogers. I’m the Assistant Compliance and Ethics Officer for ON Semiconductor.

Interviewer: Great, and please tell us a bit about your company such as what you do, global footprint, number of employees, revenue, whatever.

Mark: ON Semiconductor has about 32,000 employees worldwide. And we are an integrated device manufacturer, which means we do everything from creating silicon wafers in the Czech Republic to shipping finished products from the Philippines, Malaysia, and Singapore. And we do that about a billion units a week, so it’s a pretty complicated supply chain.

Interviewer: Awesome. Can you tell us a bit about your ethics and compliance program, your team, and your role?

Mark: Yes, I’m the Assistant Compliance and Ethics Officer. I’m also in the Law Department, so our program is within the Law Department, but day-to-day I have the people working full time on the program who report directly to me. We are very involved with our General Council as well. And we have two full-time people, one lawyer and one compliance and ethics professional working on the program full-time every day. They also support a very important program we call the CEL Team, which stands for Compliance and Ethics Liaisons. We have 37 Compliance and Ethics Liaisons around the globe. We have a Compliance and Ethics Liaison(CEL) in every major facility we have around the globe. And we try to get one in every location where we have more than 50 employees.

Interviewer: That’s a big team. So I have couple questions then about this ethical shift we’re seeing. And you’re referring to them as compliance and ethics professionals rather than just compliance, right?

Mark: Yes.

Industry Shift in Ethics and Compliance

Interviewer: So we’re witnessing this shift where strong ethics and core values are no longer nice to have and where senior management is held to a higher ethical standard. What are you seeing? You’ve been in this industry for a while. How are you seeing this shift happen? What does it look like to you?

What’s becoming clear to us is our customers expect more and more of us, our suppliers expect more, and we can’t do that through a basic program

Mark: We are seeing a shift in what we generally refer to as compliance and ethics. I think what we thought of as nice to have is absolutely required now, and it’s simply the ticket for admission. So a very basic program with a program document, a charter, a checklist, an annual training, those are all the minimum requirements now. So we work with several teams such as marketing and communications, a global security team, an internal audit team, and extensively with HR. And more and more, we’re working directly with our corporate social responsibility team because what’s becoming clear to us is our customers expect more and more of us, our suppliers expect more, and we can’t do that through a basic program.

Interviewer: Right, so with this ethical shift, how do CEOs and the ethics and compliance leaders need to think differently? How have their roles changed?

Mark: We used to think of the leader’s roles as spokespeople. Put a couple of slides in their town hall meeting presentations or have them record a video that was at the start of the training. It’s not that we don’t do that, but we do involve them in more of the close calls, the decisions, the things that present tough challenges for the team, something that’s in the grey area, maybe because of where you are in the world and with standards. There’s a lot of things we don’t need to involve them with when it’s pretty clear cut or it’s a legal call, but we are involving them in the decision-making process on tough calls more often. Because what we see is these are not clear answers and reputation and brand is a risk issue. We see these now as questions they’re going to want to weigh in on earlier in the process than I think we would have in the past.

Technology’s Role in Ethics and Compliance 

Interviewer: So how important is the role of technology in this ethical transformation?

Mark: Technology is important to the transformation in a number of ways, but it’s also still a challenge. With a global company, as many employees as we have, and in as many places as we have them, we need a global, solid platform for reporting and for maintaining the information. But we are definitely eagerly looking forward to a near future where we can tie more platforms together. We also have a very robust enterprise risk management program at the company. We also have a very strong internal audit team, and we have people who are concerned about some of the issues we’re concerned about in procurement. But there’s information in a lot of disparate systems, and it would be great to have a lot of that tied together a little bit better.

Interviewer: Great, so why did you look for a different ethics and compliance solution when you were looking at Convercent? What challenges were you facing? What forced you to do that?

Mark: When we went back to Market for a new provider for these types of solutions, we were looking for somebody that was a little more nimble, a little more customer-oriented, and one that we felt was more focused on ethics than on compliance. We also cared about a company more committed to the underlying mission and whose own mission was a little bit more aligned with ours. So we were looking for somebody who was less concerned about moving product and more concerned about helping us push ethics deeper into the organization.

Interviewer: You’ve been engaged with Convercent for a little bit now. What has your experience been with the Convercent team? You’ve got your customer success team and rep, the executive team, and customer support.

Mark: So far our experience with Convercent has been great. We have found a very supportive team, a team that’s been very willing to listen to us, to hear what’s different about our business. We have this great network of Compliance and Ethics Liaisons around the globe, so we’re coming in to report matters by proxy. But without doing more we wouldn’t have been able to distinguish the reports by proxy through CEL, through any other report by proxy. And we found the team to be very willing to dig in, understand that, help us think about how to tweak the system, then modify the intake so we could make that very important distinction for us because the CELs are such a large part of our program. So that’s just in one example, but we found the team to be very receptive and willing to listen to what’s different about our business. And that’s important to us.