Visa CCO: Ethics approach needs 'empowerment with accountability'

Compliance and ethics programs strive to ensure not only that an organization follows the rules, but also that employees do the right thing wherever possible. Visa, this year’s winner of the best compliance and ethics program (large cap) award, has taken great strides on both counts.

For Leonard Shen, chief compliance officer at Visa, ethics should be approached with the philosophy of ‘empowerment with accountability’, asking employees to examine their consciences. That comes from the much-discussed tone at the top, as well as what Shen calls the ‘tone from the middle’, and includes a focus on using examples to teach staffers.

Shen’s team was engaged in a series of nine initiatives over the awards review period, under the banner ‘Enabling business growth in a compliant and ethical manner’. These included, for the first time in the company’s history, the compliance team releasing written goals for the top business leader in each of Visa’s geographical regions, based around metrics such as setting the right compliance tone, completing compliance projects and implementing training. For example, one unit was charged with ensuring that a new product met the anti-money laundering (AML) standards of a specific jurisdiction so that the authorities of that country would enable Visa to enter the market with the product.

The degree to which leaders met these targets played a role in setting the performance ratings and bonuses for both the leaders and their staff. In addition to carrots for success, there are sticks for failure – for example, noncompletion of required compliance training can result in an employee’s access to the Visa system being limited, Shen tells Corporate Secretary.

The company also revamped its code of business conduct and its ethics and compliance training modules. The team rewrote the code to make it simpler to understand, more colloquial and more example-based, and it now also includes instructional video clips.

In addition, the compliance training modules released in the first quarter of 2017 were redesigned to be more user-friendly and less legalistic. With online training, Visa uses real-life examples and tries to keep the units short. It has also made them available over a longer period of time so employees don’t have to do them all at once. Similarly, in live training sessions, ‘war stories can be the best way to get your message across,’ Shen says.

The compliance team has also begun running AML workshops for clients, providing training and best practices to companies that Visa works with. ‘We try to educate them on our standards and expectations for their own AML programs,’ Shen says. Among other things, the team has conducted compliance roadshows in jurisdictions around the world, with a focus on Visa Europe, to provide direct in-person training and awareness for compliance with local employees.

This article originally appeared in the Winter issue of Corporate Secretary.