What are the most significant cases and transactions that your legal team has recently been involved in?

The compliance and ethics legal team is responsible for driving compliance across the region by mitigating risk exposure from an ethics and integrity perspective. Our key function is to ensure compliance with global and local laws applicable to our business including the US FCPA, UK Bribery Act, France Loi Sapin and other local anti-corruption laws and internal policies. Given that our policies are the cornerstone of our program, we are responsible for enforcing same within the company and with third parties that we work with.

In mitigating compliance risk, our role includes constant and ongoing risk management advisory, with the key goal being design, assessment, implementation, and monitoring of risk mitigation controls.

In driving compliance, we regularly collaborate with all stakeholders, which enables us to monitor and address new business risks or challenges and engage with executive management to hold employees and partners accountable for any C&E violation. We also have a reporting and whistleblowing process open to employees, third parties and customers. It enables every person who has a concern or question to log the same. This results in the team being involved in and running high profile cross-border investigations and enforcement cases. Oracle takes reports of allegations seriously and all credible reports of suspected misconduct are investigated fairly, thoroughly, and discreetly and appropriate corrective action taken where warranted.

After investigating, the team conducts risk mapping and assessments which enables the company to prioritise and swiftly address critical risk areas. One of our major initiatives based on risk mapping relates to implementation of internal controls to identify risks through transactional review. The overarching objective is to ensure that transactions involving the company’s products and services are transparent, accurately documented and executed according to applicable policies and applicable laws.

How have you attempted to bring the legal department closer to your business colleagues?   

The perception of lawyers, particularly compliance lawyers is that they are very rigid. However, working with different business executives handling different objectives and priorities, compels you to slow down, collaborate and wield the right influence because you need business stakeholders (including third parties the company engages and customers) to achieve your legal objective. I collaborate with business executives and their teams to ensure that they see the bigger picture, recognise the risk and act to dissipate that risk. This is achieved by attending business calls and meetings, being pleasant, empathetic, very responsive, solution oriented and visible to the team.

Through this, they understand that I am there to provide the requisite support to enable them to achieve their objectives. If there are conflicts, I bring everyone to the table to have an open and transparent discussion. In some situations, the risk functions are the only teams that see the risk; thus, we must remain firm and remind the team of the code of conduct and consequently, each employees ethical responsibility. The objective is to get the team to think long term and not short-term.

I collaborate with requisite stakeholders including sales, the partner management team and business operations to understand their strategy and process in order to identify possible compliance risk areas and provide solutions to address them. I provide detailed responses to their concerns, provide support, and constantly reiterate our polices and the organisation’s priorities from a compliance and ethics perspective.

In your role, how do you balance the need to protect the organisation’s interests today while also considering legal implications and opportunities that may arise in the future? 

Being a business partner, I establish requisite time-bound mitigation measures to ensure the protection of organisation and stakeholder interests; ensure that sales teams close their deals compliantly, while striving to minimise accompanying risks; proactively disseminate information to stakeholders about what can constitute red flags; and organise enablement sessions to empower them to spot risks and escalate potential concerns and ethical dilemmas, as necessary.

One of Oracle’s core values is customer satisfaction. The business teams are constantly reminded of this fact, particularly when different lines of business are pitching different products to the customer; they should never lose sight of the fact that it is one company. Not prioritising customer experience or satisfaction impacts any opportunity that may arise with the customer in the future. I also prioritise this tenet daily in relating with my internal customers – internal stakeholders.