Visa has done it again, winning the best compliance and ethics program (large cap) award for the second year in a row. Among other things, the judges commended Visa for its anti-money laundering efforts and continuously updating its program: no resting on laurels here.
Compliance professionals often point to the importance of making their work an integral part of how a business operates, and Visa has made this a cornerstone of its program. Compliance tries to emphasize that ‘we aren’t adversaries’ but work with the business, says Thuy Truong, senior analyst for compliance risk management at the financial services giant.
A key recent development highlighting this approach has been the full implementation of formalized regional scorecards including compliance performance objectives. Those objectives are set jointly by compliance and regional executives. Compliance then reviews and rates on a quarterly basis each region’s progress toward achieving the objectives.
Those reviews involve compliance officials meeting with individuals from the business side, boosting interaction between the teams, explains Betty Jo Nardozzo, Visa’s vice president for compliance risk management. The results are reported to the CEO, and the ratings factor into the annual performance ratings and bonuses for leaders and staff.
This more formalized process is part of a broader strategy of making business leaders directly accountable for ensuring strong controls and an ethical culture, according to the company. As a result of this approach, some business lines deemed to be higher risk have a dedicated head count to serve as the ‘compliance owner’ – handling compliance within the unit and liaising with the compliance team itself.
Another sign of its integration into the company’s DNA is that compliance is, as of 2017, involved in Visa’s annual business planning and strategy work. This enables the team to be involved from the start, which helps compliance tie its annual priorities to that of the business and apply the right staff as needed.
In addition, Visa in 2018 implemented an ethical manager toolkit, which is intended to help managers push the company’s leadership principles, create models for ethical behavior and offer guidance to employees who have ethical concerns or questions. The toolkit offers practical tips and resources to managers, who have been urged to include ethics discussions in their team meetings at least once or twice a year.
The toolkit includes ethical scenarios to be used as the basis of staff discussions, which are designed so as not to have obvious right-or-wrong solutions. Visa reached out to The Second City comedy group for help in making its training videos humorous and engaging.
The firm has also updated its code of business conduct and ethics after benchmarking it against 16 US companies to identify industry best practices. The updated code includes expanded coverage and improvements in areas such as harassment and discrimination, accessibility for employees with disabilities, conflicts of interest, media inquiries and the use of social media.
This article originally appeared in the latest Corporate Secretary special report. Click here to view the full publication.
Ben Maiden
Ben Maiden is the editor-at-large of Governance Intelligence, an IR Media publication, having joined the company in December 2016. He is based in New York. Ben was previously managing editor of Compliance Reporter, covering regulatory and compliance...
