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At Upright Solutions, we are so proud to be welcoming our new co-owner and Chief Operating Officer Pauline Blondet. Pauline brings a wealth of experience in Ethics & Compliance from private practice, in-house as well as from Customer Success in the Compliance technology space, working closely with dozens of Ethics & Compliance Teams. Read this interview to find out more about Pauline and her views on key trends for Ethics & Compliance.
Pauline: I became an Attorney in New York and Paris, because I really wanted to plead! I ended up working on extensive investigations from the US government into European organizations, for alleged breaches of Ethics & Compliance related regulations, as well as defending, advising and training customers in Ethics & Compliance related matters.
I entered this world from the very painful side, when organizations try to mitigate the consequences of harmful behavior that happened in the past and face a several-years-long investigation that takes up a lot of time and resources. I saw not only members of management teams having to go, but also organizations transforming deeply in this process.
I was then invited to take an in-house position in the wines & spirit industry where I could create, define and deploy a robust Ethics & Compliance strategy and program from scratch. It was so exciting to actually work to create culture in an organization, setting up a full governance: an Ethics & Compliance Committee chaired by our CEO, a network of Ethics & Compliance Correspondents worldwide, various champions. I have always wanted to create somewhat “sexy” and modern ways to sensitize our employees about issues critical to their jobs and use the right triggers so that people actually care. You want to ensure they feel supported to do the right thing, and also that they trust the system, so that they can report their concerns and let you know what you need to fix.
Of course, Ethics & Compliance teams always face the same challenge: a gigantic mountain of stuff to coordinate to impact the behavior of sometimes hundreds of thousands of employees worldwide. One needs to be super strategic and laser focused. For that, technology is no longer an option to avoid drowning your teams under a mountain of admin. I worked with a technology company as a customer and then decided to join them.
Pauline: When I joined this technology provider I led the Customer Success Team and worked with dozens of Ethics & Compliance Teams worldwide: I could see and confirm what I was feeling firsthand when I was in their seats. Even though implementing technology to manage key processes is extremely critical, we sometimes tend to miss the bigger picture still, and remain buried in so much admin, quarterly reporting, or Committee preparation that basically closes down the Ethics & Compliance office for one week!
For sure you cannot do without a whistleblowing hotline, a third party management system and so on. At the same time, the core of your Ethics & Compliance program: your 3 years strategic plan, how you work to operationalize it in your decentralized group with entities all over the world, the governance you create, your network of Ethics & Compliance correspondents, Legal, HR, finance, accounting, and other various champions: this lives in no tool!
It lives in excel spreadsheets with way too many lines, in Sharepoint folders that no one ever goes to, and in emails, thousands of them, sent to people, hoping for the best, having to follow up five times to try to track and trace who has done what and when. And of course people change positions along the way. There must be a better way, I thought - and then I met you guys!
At the end of the day, if Ethics & Compliance Teams can say how many hotline cases they have had last year, or how many third parties they have screened, that’s super important. But often enough, the most fundamental question along the lines of "have we ensured to implement a robust and adequate Ethics & Compliance program across all our offices around the world, and where do we stand precisely today" remains blurry and difficult to answer. That is, I can see, what Upright is solving in a completely different way.
Pauline: Upright offers a very affordable and pragmatic solution to solve exactly that challenge thanks to technology.
Our customers use Ethical as their overarching reporting tool - alongside traditional compliance management tools such as Whistleblowing, Due Diligence, Policy tools etc. - to draft, structure and deploy their global Ethics & Compliance programs with ease and to track results transparently.
It's the one tool I feel every customer needs who would like to create a solid governance structure and consolidate their program's KPIs and to transparently demonstrate all of their Ethics & Compliance efforts - online & offline - in one place.
As all of us “Compliance Managers” have probably experienced, adopting a new solution can sometimes be a 6 months implementation, and a lot of work with a dedicated project manager, and then you need to write an email to support every time you need something to be updated! It’s not dynamic and you end up spending way more time than you thought administering the tool.
We pride ourselves in doing the absolute opposite: our solution is implemented within days, extremely effective and 100% self-service. I really liked that when I saw this, especially coming from a background of serving customers from a Customer Success perspective.
Lastly, I realized that many companies have a huge complexity, a significant international presence without necessarily having six figures budgets dedicated to Ethics & Compliance tooling. This is also where Upright comes into play.
I can see first hand how we enable our customers to save so much time and trouble on all these accounts. This enables them to focus this newly created time and their resources on the strategic and value added parts of their roles. It feels very right.
I believe this is the future, the leading companies and Ethics & Compliance teams that are trusting us are so inspiring! I am so excited about the potential of this venture that I am joining as a co-owner: I have stakes in this and I care a lot.
Pauline: I’ll cut the fluff on AI and so on. ESG / Sustainability is coming on Ethics & Compliance desks.
As Hogan Lovells reported last summer: “Until recently, the primary external risks for many companies have been around anti-bribery and corruption (AB&C), yet with growing interest in ESG, their top worries have shifted. Of the companies surveyed, 82% told us that ESG risk is their current and future priority for business strategy.” (Companies wanting to prioritize ESG compliance face headwinds integrating ESG into their compliance programs - Hogan Lovells Navigating Deep Waters Survey, August 2022)
However, the vast majority of them cited as their top concern that ESG was not embedded in existing risk practices. Ethics & Compliance Teams have demonstrated their abilities to strategically approach risks, create networks, collaborate with all functions within their organization, compile and analyze large amounts of data to then put a plan in place to action these findings.
This is a huge opportunity for companies to build up on their existing anti-corruption practices and programs, and for Chief Ethics Officers to increase their remits further, as the “companies with strong anti-bribery and corruption policies and controls have a strong framework on which to build the governance limb on an ESG program.” (Companies wanting to prioritize ESG compliance face headwinds integrating ESG into their compliance programs - quoting Crispin Rapinet, IWCF partner in London - Hogan Lovells Navigating Deep Waters Survey, August 2022)
The EU Corporate Sustainability Reporting Directive entered into force on 5 January 2023. Approximately 50 000 companies will soon need to report on Sustainability, and this means on the following:
Now is the time to prepare! Our customers are as we speak working to put their governance & reporting frameworks in place with our solution, so that they can be ready to launch early 2024, the first year for which the reporting will be required. ESG / Sustainability is definitely likely to keep everyone busy for the years to come.
Pauline: It’s super simple. I don’t really like fluff, I want to provide our Ethics & Compliance Community with relevant, useful, practical and actionable ideas to have as much impact as possible in their organizations. Stay tuned for more to come soon, by following Upright Solutions on LinkedIn.