Case Study ECA 21/002

Ethics & Compliance Academy

Nick joined Plimens Co. recently. He was hired as EMEA Chief #Compliance Officer (CCO). In the past two months, he realized that the dynamics in his department is quite unusual, in the sense that many of his colleagues are not very committed to the company values or the message they have to convey to the rest of the company. They are very aggressive among themselves, but also with others.

The EMEA Compliance department consists in 23 Country Chief Compliance Officers, 46 Compliance Officers and another 12 Compliance Interns recruited as a selection base. The EMEA Compliance Officer has a triple reporting line: to the Plimens Co. Board of Directors, namely to the Compliance VP, the Compliance Committee and the EMEA Manager. While the country Chief Compliance Officers have only a double reporting line: to the country CEO and the EMEA CCO.

Every year, the company organizes a 3-day Compliance Summit and brings together in an online event all the Compliance professionals from all over the world. They discuss pragmatic solutions to problems they face in their daily activity, but also things that have an impact on the way they perform the job they were hired for. In about three weeks, the 5th Plimens Compliance Summit will take place and Nick was chosen to introduce the topic of the second day, which is “Making Ethics Worth the Effort!” The topic was chosen from a list of suggestions that came a few months ago from all the compliance officers.

The previous EMEA CCO, a well respected guy in his field not only at national and international level, left the company after only 9 months. Nick doesn’t have a clue on why this happen, but he suspects that there was a conflict between the former EMEA CCO and the country CCO. When he searched on LinkedIn, he learned that that guy was immediately hired by the biggest company in their industry as EMEA CCO.

One week ago, the Compliance VP received an anonymous email complianing about the attitude of the Austria CCO and the fact that the local Compliance Officers provided an opinion that clearly contradicted the law. At the same time, the author of the email mentioned a conflict between the EMEA CCO and the Austria CCO that took place in front of everyone, including a business partner. But the email did not mention the name of the EMEA CCO.

When the Compliance VP confronted the EMEA CCO during a Zoom meeting, he denied the allegations and even mentioned the fact that he never had any direct argument with any of his peers. Not even during a phone conversation. As a matter a fact, he informed the Compliance VP that he thinks that there is a toxic climate in the entire department and has some ideas on how to address this issue. But for doing this, he needs the CEO and the Compliance VP to send a specific message at the Plimens Compliance Summit. He asked the Compliance VP if they can meet again on this subject, but he received a hesitant answer.

One week before the internal compliance event, the EMEA CCO received an email from the Compliance VP informing him that he is no longer required to introduce the topic of the second day of the summit and that his department will be subjected to an audit mission. What should Nick do?


Copyright (C) 2021, Cristian Ducu. All rights reserved.

Author(s): Cristian Ducu

General Area: Business Ethics

Specialized Field: Ethics & Compliance

Keywords: Compliance function, Ethical Climate, Organizational climate, Organizational misconduct, Whistleblowing, Workplace conflict


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