In an article entitled "Learning
to Work with Green Activists" published in this month's Harvard Business Review, Chairman, President
and Chief Executive Officer (CEO) of Duke Energy, James E. Rogers, writes about
his experiences early in his tenure where he embarked on "100 Days of
Listening" during the first few months on the job. His initial idea was to meet
with as many company stakeholders as he could before taking substantive action
in his new position as CEO to Public Service Indiana (PSI), the predecessor of
Duke Energy. After some consideration and (apparent) gnashing of corporate
teeth, he decided to add a group to this list which was not traditionally
viewed as a group of PSI stakeholders - environmental activists. The results
from this last decision have an interesting application to the maintenance of a
corporate compliance program.
From listening to these various environmental groups,
Rogers decided that PSI needed to integrate environmental risks into the
company's decision making calculus. To facilitate that effort Rogers decided to
create an environmental charter. This ten-point charter has been used as a
guidepost when PSI, and now Duke Energy, approaches environmental issues. We
reviewed this environmental charter and believe that it is a very useful
approach for a company to take in the area of compliance, so with a tip of the
hat towards Rogers' work at PSI and Duke Energy, we use it as the basis of a
Compliance Charter for today's post.
We hope that this list will provide you with some ideas
that you can incorporate into your compliance program. But more importantly we
hope that Rogers' experiences will remind you that a key part of any successful
corporate program is listening.
Want to hear more from Thomas Fox, add these webinars and
World-Check FCPA Road Show events to your calendar:
II. World-Check FCPA Road Shows.
Co-presenting with Stephen Martin, General Counsel of
Corpedia, on "Anti-Corruption/FCPA Developments & Best Practices"
I hope you can attend the webinars, and if you are in
Phoenix or San Diego, come out to 'listen' to myself and Stephen Martin.
Visit the FCPA Compliance and Ethics Blog,
hosted by Thomas Fox, for more commentary on FCPA compliance, indemnities and
other forms of risk management for a worldwide energy practice, tax issues
faced by multi-national US companies, insurance coverage issues and protection
of trade secrets.
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© Thomas R. Fox, 2011
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