Greg Triguba, Principal of Compliance Integrity Solutions in Seattle, Washington, USA
Greg Triguba (greg.triguba@compliance-integrity.com) was interviewed in February by Adam Turteltaub (adam.turteltaub@corporatecompliance.org), Vice President, Strategic Initiatives & International Programs at SCCE & HCCA.
AT: Let’s start with your compliance roots. You began your career in the military. What led you to the service, and how were you introduced to a career in compliance?
GT: I have always appreciated those who serve and are giving something back. Both my father and older brother served in the military, so it was an easy decision that led me to nearly a decade of service in the Air Force.
When you think about the importance of compliance, ethics, and culture to organizational success, military service embraces these concepts in a meaningful way, and it provided me with an excellent career foundation. Core values such as honor, integrity, ethics, and teamwork are fundamental to serving, including the importance of compliance with the letter and spirit of regulations and guidelines that help drive the military mission around the world and make it successful.
My roles during this time were heavily focused on compliance and human resources management that included monitoring and auditing, training and communications, and other “people” programs. This experience provided me with a deep appreciation for how ethics and compliance play an important role in an organization, and was instrumental to instilling in me a passion for this work early in my career.
AT: Since that time, you have established a long and successful career in ethics and compliance in your civilian life. What has kept you interested and focused on this career path?
GT: When you find a profession where you truly enjoy the work, believe in what you are doing, and can see the positive impact and value it brings, it serves as a strong indicator that you have chosen the right path. This has been true for me from the beginning and has continued throughout my career.
I am passionate about this profession and feel fortunate to bring a deep background and skill set to the practice that has been very helpful and complementary to the work we do. Some important influences include artist parents who encouraged creativity, service in the military, a legal perspective as a licensed attorney, inspiration and insights gained from colleagues and mentors, and hands-on experience in both in-house and consultancy roles in ethics and compliance across industries, including retail, telecom, technology, financial services, transportation, nonprofit, construction, government, and insurance. All of this has helped to equip me with a greater understanding of how effective ethics and compliance programs and good risk management makes a positive difference in organizations across cultures on a global scale.
Over the years, I have gained expertise and insights on successful strategies and approaches for building and implementing meaningful programs from the ground up, as well as an appreciation for how partners and cross-functional groups within an organization contribute to its success. I have worked with, and been part of, ethics and compliance programs at various levels of development and maturity, including start-up programs, companies facing regulatory and enforcement challenges, and others that just want to enhance their program effectiveness. I am inspired by this work and value opportunities to contribute and make a positive impact on organizations in efforts to mitigate compliance risk, enhance cultures, and take ethics and compliance programs to the next level.
AT: You’re proof that there isn’t one defined way into our profession. What would you tell someone interested in pursuing a career in compliance?
GT: This is one of the greatest professions on the planet! There is great demand for what we do, and our work is needed now more than ever as organizations become more global, complex, and increasingly regulated. When you consider the opportunities we have in our profession to help influence an organization at every level regarding ethics, compliance, integrity, and culture, it is hard to find a more satisfying and rewarding career.
We all bring our experience to this practice—perhaps from the operations of the business or other disciplines—and this translates well to the work we do. As a great example, folks new to the profession can sometimes feel that they may not have enough experience to contribute and bring value right away, but some of the best ideas for ethics and compliance programs often come from the new people. They bring fresh ideas and perspectives to the practice that help keep our efforts current and relevant.
There will always be a need for talented and skilled people who care about this work and want to make a difference. One important consideration to doing well in this profession is our ability to influence, bring people together, and excite others about integrity, ethics, and compliance. Not an easy task, but feeling passion for this work as a starting place is an important first step to success.
AT: You and I go back a long way. I recall one of the very first times we met was at the first question writing sessions for the Certified Compliance and Ethics Professional (CCEP)® exam and the creation of the credentialing standards. You were at Eddie Bauer then, and I was at LRN. What led you to make the sizable time investment to help create the certification?
GT: Seems like just yesterday Adam, but yes, it was a long way back! SCCE was just taking off, and recognizing ethics and compliance experience through credentialing was an important step in the evolution.
At the time, I was working in-house, building an ethics and compliance program. I was invited to collaborate and brainstorm with a small group of other experienced practitioners and subject-matter experts across industries regarding what important factors and best practices should be considered when building and implementing effective programs. Our discussions extended beyond mainstream effectiveness elements and focused on real-world experiences, challenges, and strategies that are essential considerations when establishing and maintaining meaningful ethics and compliance programs, and addressing related risks.
I recognized the value and importance of this work early on, and have stayed committed to it. It has been a privilege to serve on the certification and testing committee from its inception and watch it grow from its humble beginnings to what is now among the most important credentials in our profession.
AT: Since then, it’s become an even bigger part of your life. You’re on the faculty for the SCCE academies, both domestically and internationally, and contribute in many other ways to the organization. It must be rewarding seeing certification and our academies grow from an idea into an institution.
GT: One of the most rewarding aspects of my involvement with SCCE has been serving on the committee and contributing my insights and expertise to the process. Equally rewarding is seeing SCCE community colleagues achieve professional and personal success by adding this credential to help validate their skills and experience. It tells the world you have the requisite knowledge and commitment, and understand the responsibility to help drive and manage successful ethics and compliance programs. For these reasons, we now see it on many ethics and compliance job postings as a valued competency.
At our academies, the perspectives and experiences shared by colleagues who attend from around the world regarding their program successes, challenges, and strategies are insightful and important to understanding the realities of real-world practice across industries, cultures, and disciplines. For me, the opportunity to collaborate, gain insights, and share best practices with them has been invaluable.
AT: One of the things that strikes me at our international academies is seeing how important having a certification is outside the country. It seems that it is often more important what certification you have than what degree you earned in college or graduate school. As a faculty member, do you get that sense? Do you find the students are different?
GT: Professional credentials and education are perceived and valued differently in various cultures, but a primary benefit from the academy is how concepts and insights gained during the course can be leveraged to make ethics and compliance programs more meaningful. The credential itself is a great thing to achieve, but the real value is the knowledge and expertise that lives behind it.
The academies offer more than just an opportunity to help compliance professionals achieve a credential. Colleagues who attend and participate beyond this objective are more likely to gain helpful practice insights from the program curriculum, take advantage of the unique networking opportunities provided, and leverage the overall experience as an active forum for sharing ideas and important practice considerations. From this perspective, I don't see a major difference among colleagues who attend from around the world.
AT: One of the topics you teach is incentives, and that’s a tough one, because organizations struggle with how to create the right incentives. Many people feel that there shouldn’t be incentives for doing the right thing, that virtue must be its own reward. What’s your feeling about the role of incentives and how to create effective and appropriate ones?
GT: Great question and a topic that can be somewhat controversial. When considering ethics and compliance program effectiveness, we often focus on how well we identify and address wrongdoing. Not enough attention is typically given on what we are doing in our organizations proactively to promote and reward ethics and compliant conduct in a positive way. Shifting our focus to include this positive consideration can go a long way to help prevent bad things from happening in the first place.
Every organization should consider recognizing and rewarding leadership in ethics and compliance as part of its efforts to proactively instill these important values into the DNA of the organization. A great start is to include these standards and related expectations into performance evaluations. It sends a powerful message to employees that ethics, compliance, and integrity matter as part of their day-to-day performance and that management cares about it. To not include it sends the wrong message.
For those organizations that may not be doing this already, consider partnering with human resources to include these standards as part of the process; make it an important factor when evaluating performance, promotions, bonuses, and other opportunities. Be persistent in influencing and advocating the value of why it matters. If someone pushes back, you should be asking why!
AT: In addition to financial and other hard incentives for people to do the right thing—and penalties for doing the wrong thing, for that matter—behaviors get shaped by cultures. And here I’m talking about corporate culture. To me, it’s amazing how pervasive a company’s culture is, and yet people often are unaware of it. We talk a great deal about the need for the compliance and ethics program to shape the culture. How realistic do you think this is?
GT: Effective ethics and compliance programs play a significant role in corporate culture and make a difference when it comes to raising awareness and improving the bottom line of successful organizations.
Studies have shown that when outcomes of our efforts result in stronger ethical and compliant cultures, organizations can benefit from, among other things, higher employee engagement, performance, and retention; an improved corporate reputation; recruitment advantages; and lower levels of misconduct—all of which result in a healthier bottom line. Once leadership has a better understanding that effective programs can help to drive these positive benefits, it will go a long way toward getting the support you need for additional resources and budgets.
If ethics and compliance is deeply rooted into an organization’s culture and DNA, and employees genuinely care about doing the right thing, it is very likely that they will do every aspect of their jobs better. This will certainly have a positive effect on the business!
AT: What are some concrete things compliance programs can do to help get the right culture when it comes to integrity and lawful behavior?
GT: Much of what we do to build and implement effective ethics and compliance programs has a direct and positive impact on culture.
To touch on a few high-level practice considerations that are central to our efforts, here are some good examples: (1) Facilitate and support leadership and middle management in their efforts to promote a positive tone for ethics, compliance, and integrity; (2) actively promote a culture of fairness and organizational justice, and take steps to create and maintain an environment where employees feel safe seeking help and reporting concerns (including monitoring and addressing negative outcomes); (3) implement a meaningful code of conduct that speaks to the organization’s values and sets the right tone and expectations for ethical conduct; (4) create and advance ongoing communications and training that emphasize the importance of integrity and ethics to the organization at every level; and (5) incorporate ethics and compliance standards into performance management systems and take steps to reward ethical conduct and leadership when warranted.
These examples just scratch the surface on the many ways that good ethics and compliance programs can affect ethical culture, and doing these things well will certainly help to drive and enable the right behaviors.
AT: Doing things right starts with a risk-based approach. You want to stay focused on the important things. What do you find makes for the most effective compliance risk management process?
GT: When making decisions on where to allocate resources and budgets to most effectively manage risk, establishing a risk-based approach and methodology from the onset is vital to the process. Given that it is not practical to address all compliance risks facing the organization at the same time, taking steps to prioritize and focus on the highest risks first will help to ensure you are working on the right things, at the right time, and with the right resources.
For those just getting started in this effort, an important first step in the process is to identify and inventory the universe of all the compliance risks facing the organization and establish a dashboard of top risks to consider for further assessment, prioritization, and management. In many cases, identified risks may already be managed and addressed, but this process is helpful to consider any potential gaps and where you should focus your efforts.
Leveraging both internal and external inputs to help you effectively identify the organization’s risk universe, among other things, is important to this effort, and seeking input from management throughout the risk management process is invaluable to making it work well.
AT: Finally, how do you see the profession evolving?
GT: Given the complexity of rapidly changing landscapes and risk for organizations in areas such as technology, cybersecurity, privacy, trade and regulatory changes, social media and enforcement trends, among others, there has never been a greater need for the work that ethics and compliance professionals do each day. Part of this includes continuing our education and awareness related to these risk areas, partnering with relevant subject-matters experts, and honing our skills to better serve us as we take steps to manage and mitigate them.
To touch on one important example here, ethics and compliance practitioners should continue to be vigilant in our efforts to better understand and stay on top of the risks related to technology. Technological advances that affect organizations now and in the future (such as artificial intelligence) are moving a mile a minute. Staying knowledgeable helps us to be proactive in assisting our organizations to adapt and manage these associated risks more effectively. This gives us a better opportunity to provide relevant guidance and training to members of our organization regarding ethical considerations and doing the right thing in this dynamic and evolving area.
AT: Thank you, Greg, for sharing your insights with our readers.