“When advancing company culture, you need to find a natural way to embed business ethics into people’s everyday jobs,” said Chad T. Jerdee, Accenture’s general counsel and chief compliance officer.
Compliance is a massive challenge for any global company. As Accenture operates in 120 countries, Jerdee helps the global management consultancy keep its 442,000 people all on the same page. The firm’s ongoing ethics training is frequently refreshed. Technology also drives compliance efforts.
Learn how Jerdee helps implement anti-corruption measures company wide—and the role AI and data analytics tools play in that vision. “Evolving tools can help us ensure we comply with laws no matter where we do business,” Jerdee said.
How do you help ensure Accenture stays ahead of the kind of fraud challenges routinely faced by global companies?
One of the things we try to achieve is efficiency—specifically, for people to get the guidance they need on the compliance front through the right tools. Accenture is in 120 countries, and has approximately 442,000 people. We also have a lot of third-party business intermediaries, in different markets.
We have built a platform for our business people to log in and submit any intermediaries for approval. We have an accompanying team focused on making sure we quickly do due diligence into all of them.
We also have a global gifts-and-entertainment tool, where people can quickly assess if a gift or entertainment, whether for a government or a non-government client, is appropriate. Sometimes the assessment is purely automated, when, for example, it is clearly within policy and no red flags are raised.
Other times, if you check the government official box or the gift exceeds a certain threshold, it will be flagged for further review. Then we’ll have somebody assigned to the case to advise the person.
In addition to these tools, what other measures help foster compliance?
In our program as a whole, we hire top-flight outside counsel—ex-Department of Justice prosecutors now in private practice, for example—to help us do risk assessments of our entire program. We do a full assessment every three years, and continuous program reviews in between that go directly to me to identify both emerging risks and any enhancements needed for processes and controls.
We’re also constantly refreshing training, in light of new and emerging risks. Our training is not an off-the-shelf, one-time thing. We work with our advisors to put ethics in the Accenture context, making it relevant to people and what they do in the field.
What role do technologies like artificial intelligence play in addressing multi-jurisdictional actions and investigations?
Because of their ability to look at masses of data and track trends across a portfolio, AI and accompanying analytics tools have huge potential to help detect potential problems and confirm compliance.
For example, in gifts and entertainment, we can compare compliance controls and trends with expenses that people actually submit and look for red flags. That gives us greater insight, and makes the process not only better but faster and more efficient.
This technology can also help us adjust quickly as rules and regulations change. Evolving tools can help us ensure we comply with laws no matter where we do business.
How does Accenture’s recently launched internal chatbot, COBE (Code of Business Ethics), also advance ethical standards across the company?
When advancing company culture, you need to find a natural way to embed business ethics into people’s everyday jobs. So, first and foremost, our goal was to make our code accessible and easy to interact with—in other words, to offer a simple way for our employees to ask questions and search for answers.
To date, we’ve had more than 285,000 unique visits to our new Code of Business Ethics website, and more than 61,400 COBE chatbot sessions since its launch in late 2017. All the interactions with the chatbot are anonymous, but we do track the questions and accompanying trends so we can constantly enhance the content.
There’s where we’re applying artificial intelligence. Based on interactions with people and the feedback that we get from the chatbot, we’re enhancing how the questions are answered.
The technology can adapt based on inputs, which is phenomenal, and in turn increase the satisfaction rate—and impact—of the program over time. Ultimately, we see technology like this as a way of engaging with our employees worldwide, where even if you can’t always have conversations with them human to human, you can provide them something they can interact with that helps increase questions asked—and leads to better compliance.
What other legal and regulatory compliance programs enable Accenture to operate around the globe while adhering to ethical standards?
At Accenture, our core values underpin everything we do, including what we call a “Conduct Counts Program,” where we educate our people on our high standards for employee behavior, including ethics and compliance, and survey all of our employees to get feedback on what they see day to day.
Through programs like these, we also hold ourselves and our leadership accountable in all countries where we do business, and work with them to create programs specific to local trends to reinforce ethics, including anti-corruption measures.
This approach has served us well, because, if you look at some of the countries where we do business, we’ve got strong compliance programs and a reputation for being an ethical company, where other companies are struggling.
I’m also a member of our Global Management Committee, consisting of our top 20 leaders, led by our CEO, Pierre Nanterme. We speak about compliance regularly and our CEO reinforces our commitment to running a compliant business, and through this committee, also ensures we set the right tone from the top.
How does your personal commitment to Accenture’s Persons with Disabilities Program, as well as the Challenged Athletes Foundation, inform your work?
My commitment is fueled by the intersection of two things. At Accenture, we believe different points of view that come from a diverse workforce assist us in delivering better results to our clients.
The other intersection is through my personal experience. I was hit head-on by a drunk driver a few years ago, and I lost my lower left leg. I spent quite a bit of time in a wheelchair, and then adjusting to a prosthetic. That experience led me to realize the sense of separation and difference that a lot of people with disabilities have, and the assumptions that people make about them, particularly their perceived limitations.
In retrospect, the [car crash] was a profoundly good experience in that it made me more sensitive to the challenges faced by talented people with disabilities. Today I sit on our Global Diversity Committee and am the chief sponsor of our people with disabilities program.
We’ve been able to significantly enhance our program, and move beyond simply providing things like reasonable accommodations, and legal compliance, toward fostering a culture that understands and embraces people with disabilities, and makes them an equal partner with all other categories on diversity.
What we can expect next from Accenture and your team, particularly on the anti-corruption compliance front?
I think the biggest thing you can expect is the continuation of technology to transform legal compliance and anti-corruption measures. We are currently in an environment where digital technologies, like analytics and artificial intelligence, are only just starting to show their potential, and I think Accenture, particularly given this open scale on which we operate, can be a real role model of the application of these technologies in corporate compliance programs.
We also believe that any program—any technology—starts with the people using it, so we use what we call design-led thinking.
As opposed to forcing an employee to go through your program, we think it’s important to create an experience for them, like our chatbot, which makes it easy for them to understand, interact, and ultimately comply with anti-corruption and other laws. Leveraging technology as we are to foster anti-corruption measures is exciting—it’s a great opportunity.
This profile originally appeared in In-House In Brief, a biweekly newsletter of Big Law Business and the In-House Council. To receive up-to-the-minute news and analysis curated specifically for in-house counsel, subscribe for free today.