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Corporate Culture-Sonia Luna Interviews Allyson Bouldon

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Allyson Bouldon is Vice President and Chief Compliance Officer at Chiquita Brands International. Chiquita is a leading international marketer and distributor of high-quality fresh food products including Chiquita® bananas and Fresh Express® salads, with over 21,000 employees on 6 continents. Prior to joining Chiquita, Allyson was Assistant General Counsel, Labor and Compliance for Mead Johnson Nutrition Company and also served as Vice President and General Counsel of Tegrant Corporation.  She is a graduate of The Law School at the University of Chicago and Dartmouth College. Ms. Bouldon is Past President of the Association of Corporate Counsel, Chicago Chapter, a Fellow of the American Bar Foundation, an author, and speaker.   She will be a presenter at the Compliance & Ethics Institute Conference in Chicago, Sept. 14th-17th.  Her workshop is entitled: Don’t Let Culture Happen to You:  Understanding and Leveraging Your Culture for Ethics & Compliance Effectiveness


0:06 Sonia Luna

Hi! I'm Sonia Luna, CEO and founder of Aviva Spectrum, an internal audit and compliance consulting firm headquartered in sunny Los Angeles, California. I am also a speaker and writer on topics like COSO 2013, SOX 404, Quality Assessment Reviews, Internal Auditing and related topics. Today's interview which I'm really excited about is with Allyson Boulden. Allyson Boulden is a VP and Chief Compliance Officer at Chiquita Brands International. Chiquita for those of you have been living under a rock, is the leading international marketer and distributor of high quality fresh food products including Chiquita bananas and fresh express salads with over a 21,000 employees on 60 per continents. Prior to joining Chiquita, Allyson was a Assistant General Counsel of Labor and Compliance for Mead Johnson Nutrition Company and also served as a VP and General Counsel to Tegrant Corporation. She is a graduate of the Law School at the University of Chicago and Dartmouth College. Ms Boulden is past president of the Association of Corporate Counsel in the Chicago Chapter and is a fellow of the American Bar Foundation and author and speaker, as a matter of fact she will be a presenter at the Compliance and Ethics Institute Conference in Chicago, September 14 through the September 17. Her workshop is entitled "Hey! Don't Let Culture Happen To You: Understanding and Leveraging Your Culture for Ethics and Compliance Effectiveness" which you can register for the conference at www.complianceethicsinstitute.org. Welcome! Allyson it's a pleasure to have you on our show.

2:00 Allyson Boulden

Thank you Sonia. I'm happy to be here.

2:03 Sonia Luna

Well, I know, we have been hunting you down for quite sometime (laughs) try to get somebody in the counsel space to talk about this exact issue. Okay and one of the things that we we're coming up with in terms of what our listeners wanted to know most about was -- you know how does a compliance executive, okay, first measure what type of culture, okay, that they have and then how should they align that culture to core business strategies?

2:36 Allyson Boulden

Certainly. Well, Sonia this is the key to termination and, you know, the assessment can start as early as the interview process. So, for public company she might want to take a look at the types of the compliance and ethics documents that are posted on the company's website is there corporate government guidance posted for the board of directors, is that a code of conduct if so what is the tone of that code are relevant regulatory development listed on the website is there supplier data, what does the privacy information look like all of these things can provide very helpful windows into the company's culture and of course once you're on site you have the benefit of revealing recent employee surveys, compliance risks reviews, ER and risks reviews, these are all valuable resources. I'm also a very, very strong believer in face to face introductory meetings, especially if you are working across several geographies and cultures because you need to build that rapport and through building that rapport you can learn about the business strategies at a deeper level than what you will receive if you solely read the business strategy documents that the company may have.

3:49 Sonia Luna

So it's not just going through what's available, let's say to the public that also that face to face rapport building exercise and really getting a sense of, okay here are the words and these people are also validating those words on different documents that are available and then, hopefully there is some action obviously behind those words to align to say, you know what this, they mean what they say because I can see that they're doing exactly what they say they're gonna be doing. So, that's one way of kind of aligning in themes like that what you're saying is obviously starts from the very obvious which is okay there is plenty of stuff especially if it's a public company and I completely agree with you there is a ton of documents that someone could read. But then it's a human it's not face to face interaction getting or again being in touch with those folks in the field or any operation sort to speak, telling that is kind of one of the best practices that you've learned over the years.

4:48 Allyson Boulden

Absolutely, especially, again if you're going across cultures in the US, we are pretty open as for cultural perspective, so we are fine with phone calls and social media and email outreach, but defending on where you are in the world. It really helps if you make that life touch or at the very least the personal touch meaning a personal letter or personal email, something that shows the recipient that you are reaching out to meet with them and to better understand then their business challenges their day-to-day work and how you can help. So, yes I'm a huge fan of face to face live meetings if your budget permits and you know the other item that I call out that I think can be very helpful is recently employee surveys. If those surveys are done anonymously you'll often get frankly very open feedback from employees and that can be very variable as well.

5:54 Sonia Luna

Yeah, it's a good indicator of what of, especially, like you stated earlier I mean anonymous, people are more open to share their true (laughs) their true words when they're really are -- when they know it's anonymous and they know that there's no, you know, it's hard to find out who exactly said certain things or wrote certain things, which leads me into something that, I was recently in the conference this week actually and we talking about emails and then this concept of mega data okay and I wanted to kinda get your thoughts just best practice that's okay, what do you think is the most effective way in an organization can gather and use data. Okay, to predict or forecast sort to analyze, let's say compliance risks because there's just so much data out there a number of transaction, emails all kinds of stuff. I mean, what you have seen as the either the best practice or let's say a leading trend that works best for larger organizations?

7:05 Allyson Boulden

Sure! Well, I would say taking a look at your historic helpline data can be a great indicator of potential risks, so if you are a subject to the SOX guidelines you're offering away from employees to call anonymously, we're permitted by local laws to ask questions or raise concerns. Here we call that processor helpline and that data is just very, very helpful you can see whether you are getting patterns meaning a lot of call from certain geographies or if you are getting repeat of issues and all of that can be very, very helpful. Other things that can be very helpful are discussion with your internal business partners, the internal audit group members for example, tend to be very, very knowledgeable and they can be very helpful to compliance because they typically have people on the ground, they are very well-versed in the company's policies and procedures and because of their audit work they are up close and personal and they see what works and what hasn't work as well.

8:11 Sonia Luna

And what lessons do you think have you seen in the field where a larger organization can extract, you know the best sets of data because I am noticing and this is where I was gotta come in with the questions that we see more JPEG files, we see more, you know, WAV files, we see text obviously file, so we see a number of time files and to do compliance. Right, it's, you know a practitioner really needs to get a code of best of brief practice of how to get that best sets of data. Have you seen anything in the field that you have seen works really, really or things that it just mediocre and our technology haven't evolved yet, I mean what's your thought on that?

9:03 Allyson Boulden

So, I think many companies are evolving their technologies but I suspect that most have not gotten to their in point just yet. First of all, depending on we are in the world there are privacy restrictions and so even you have the technology to call your emails and call all of the files that folks have on their, their shared drives, so with their personal drives there could be restrictions to the company seeking to do that, so I think I typically seen is live interviews, reviews of helpline data, employ E surveys and then review of the actual data that the system has only in specific cases so if there's in a investigation or if we are literally trying to find instances where certain policies came into focus. Those of the cases were we would literally be calling the data but otherwise I think it can be a little bit fraud.

10:08 Sonia Luna

Uh-um, uh-um. Yeah, it's we're experiencing something similar where our clients have just a bunch of data and you're right they are different laws and regulations in different countries and they are free to have been sensitive to those issues, but honing on what matters most in getting a good plan together, I think what we have found one of the best ways of a good starting point because there is just a ton of data and it can be sitting in a lot of different places. So, it's coming up with the formulated plan that I think kind of agrees to and then executing on that plan. I think technology is (crosstalk). Yeah, go ahead.

10:49 Allyson Boulden

And Sonia one thing I think I can add there is, to your point what I am saying is the companies are relying more and more on technology solutions for certain functions and so for example job applicants slow through a certain technology procurement will have a technology that takes the procurement function from starts to finish. In our compliance group we will have a helpline that tracks the activity and so that makes that a little bit easier if you need to understand data such -- you know what you're third party vendor profile looks like or whether you're having spikes and certain types of helpline claims.

11:28 Sonia Luna

Yeah, and I like the word that you said types because in my audit the nerdy word we call them categorization, you know, if this is a sexual harassment issues, you know, foreign crafts prior to do that I mean we put them in auditor let's put things in buckets so, (laughs) could this "types" and I want to kind of switch away from a little bit from risk to opportunities, okay.

11:56 Allyson Boulden


11:57 Sonia Luna

I mean have you seen any, you know, or let's say the tops re-opportunities that just in your professional experience you've discover that on organization like "Hey, you know what that, that was a great eye opening experience" we actually capitalized on something that benefited the company, you follow, that you are aligning the culture to strategy. I mean, have you seen that in your professional experience?

12:22 Allyson Boulden

I have, I've seen it where I am currently here at Chiquita and I have also seen it with other companies I've worked with them in the past. So, I think there are three large buckets that present a biggest opportunity for many companies today. I think the first is to stay the privacy program development which includes development of data bridge protocols. I thinks that's a hot area because many companies are now transacting business globally and in order to do that in a way to provides the most flexibility to the company it's great if you can do things like obtain US Safe Harbor Data Privacy Status or are we going to the binding resolutions another means of protecting the flow of data across continents And then of course, data breach protocols, data breach has been all over the news. If you are doing marketing, if you are taking consumer information, if any of your business customers are smaller mom and pop stores, you could be receiving personal information as part of those touches. And so, what does your date breach program look like? Do you have a protocol? Do you have a crisis plan? Do you the involved folks know exactly what their roles are and what they would need to do in the unfortunate event that something occurred. So I think that is a big opportunity area for many companies.

13:57 Allyson Boulden

A second area that I think is just really right there for many companies is encouraging employees and third parties to speak up with questions or concerns and, you know, that includes embracing anti-retaliation. There are so many whistle blowers statutes out there now that actually provide financial incentive to individuals to come to government agencies to air their concerns. And if you are working for a company, well my goodness, you want to know if third parties or employees have those concerns so that you can take immediate responsive action. So I think, we are all doing all we can to encourage employees and others to speak up and to stress the protections.

14:45 Sonia Luna

Yeah I know, it has been on the news, especially for a major retailer about their data breach, there was a cyber security attack. But you are right. I mean, it is only when something terrible happens, then people go "wait what was the policy again? What we are supposed to do?" It is kind of that emergency kit that you know you had it, right? It is in the house, it is there but you forgot what is in it you know?

15:13 Allyson Boulden


15:14 Sonia Luna

And you don't, you don't want an emergency to happen to when you think of, "now I need to go to that kit". It is the same thing with policies employees. When we audit anyways, we notice that the on-boarding process makes them pretty much signed that they have acknowledged and understood everything. Okay? Yet the employee manual is about 50 pages, the other handbooks are another 75 pages and you are expecting an individual to really digest it, you know, like a sponge, they have absorbed all of that information and to your point, the opportunity, I mean, training people on the latest policies especially after they get updated and understand the benefit of the company and to them is a critical opportunity. It creates better dialog I have found in practice. Employees feel -- there was a study done with, believe or not, accountants of all people, how they felt when their accounting firm, okay their accounting firm had, not only conservative ethics and policies, but continuous training on that topic like you cannot invest in a company that you are auditing. You are not independent right?

16:25 Allyson Boulden


16:27 Sonia Luna

They found that the job satisfaction of having an employer like that went up. So, there is a correlation to, not only working for a company that has strong ethics, but training and telling them what the benefit is and the why factor, why do we have these policies and places. Because you know, we want an even playing field. So that way, you know, if your are auditing them they don't think that you have some hidden agenda by making them pass let's say an audit because you have an investment in them. Uhm and I wanted to kind of get into a quick, minor 30-second story. I had dinner with one of my professors, Glenn Gray. And he is constantly scratching his head about what do employers really want. Okay, and he'll get one answer from one employer and then he'll get a different answer from a different type of employer and they are in different industries, okay. So, I wanted to ask you, what did you see, okay, as skill sets that you think are needed in the compliance space to be, you know, a person that can successfully execute an alignment of culture and strategy?

17:43 Allyson Boulden

Wow, okay. That is really the bottom line question. And you know, I think compliance is a wonderful space first of all. It is very fulfilling. It requires great creativity, it requires an interest in people. Personally, I find people to be very interesting. I think that you always get surprises when you are working with other people and I think that is one of the most inspiring things about compliance work. But in addition, I think it helps to have diplomatic skills, EQ and broad substantive regulatory knowledge. Because you do need the substantive regulatory knowledge to address situations as they arise and to have that sense of how things may unfold. Because what starts as a simple help line inquiry along the lines of gee, you know, this is something that my boss said to me and you know, I did not appreciate but you know, i am okay. Well, there could be a lot more to that situation. Similarly, another hot area is development of controls to prevent fraud, corruption or bribery and there have just been updates to the COSA framework for example. So someone could say something very simple to you along the lines of "gee, you know I used to be second signatory, I am these types of financial documents, but you know, I was told that I do not have to that anymore". Standing alone that comment may be absolutely acceptable but if you do have that regulatory background, you might know to inquire a little bit more, just to confirm that processes and protocols are still in place.

19:37 Allyson Boulden

So, I think that those skills, the diplomacy skills, the broad substantive knowledge are all helpful for compliance. Maturity helps too. You know, for better or worse in the compliance space, you are sometimes dealing with difficult situations and you are coming in at a place and time when emotions maybe high and so you need the ability to address the situations, discharge your obligations and duties, but also not be unduly upsetting to the persons you are interacting with.

20:20 Sonia Luna

Uh-hm. Yeah, it takes some really core interview skills and like you stated earlier, diplomacy and kind of being the cooler head in the room. You know, it does take experience. I mean, I can tell you when I first joined Arthur Anderson, my interview skills were pathetic. I get to you know, 16+ years later, it's a different scenario and it's not.

20:49 Allyson Boulden


20:50 Sonia Luna

I mean, trust me when I said that. I have read books and I have understood and every year I have certain sets of my own personal vaults for reading, for both soft skills and just technical skills, I have two sets. But here's the point, you have to have a lot of practice and sometimes, it does take years to develop. It is not something you can get as a graduate and just say, "Boom, I want you to do this perfectly". It does take time to develop those key skills and the diplomacy piece, I really gravitated towards that statement that you mentioned. In our world, most of our audit colleagues call it the data is the data is the data and we use that in context of do not get mad at me, these are the facts. You know, let's not make this too much of a personal issue, it is what it is, you know. Now, most auditors who are people, people, okay, we want to move on to solutions. We basically move forward on this issue because again, the data is the data is the data in our world. So.

22:02 Allyson Boulden

Sure, and it's a great point. And by the way, I have a feeling that you're just being very humble about the skills that you were bringing to the table from the very beginning of your career so I just wanted to add that.

22:15 Sonia Luna

Oh, well thank you. I mean, maybe it is in my nature. It's the Latina nature in me. (laughs) So I am graded and then, because I can always move up Allyson, that's the whole point. And I wanted to get to your story Allyson, because everyone has a story how they got into this compliance arena. Okay. So could you please share your story how, to our listeners, you know, what drew you to your current compliance position? What was the big draw factor?

22:52 Allyson Boulden

Well, I am a practicing attorney and I started off as a commercial litigator. Eventually, I went in house and through a series of in-house roles, I was able to expand into areas like data privacy and employment and contact review and antitrust counseling and I really enjoyed all of those areas. And I found that the compliance arena was just to me, a great fit, because it allowed me to interact with people but also to bring, to bear the legal skills that I have developed overtime, and I got to working in some of my favorite areas including data privacy and antitrust counseling and employment laws. So I just thought it was a very, very interesting area. No two days are ever alike and the formal litigator in me likes that. You know, they say transactional lawyers and litigators have different personality types and you know, I am not here to settle that debate but I can tell you that as a former litigator, I love pace and change and learning and relearning and persuasion.

24:14 Sonia Luna

Uh-hum. Yeah. And it is an interesting journey because people, what I have found, some people when they have gotten into this space, if you will, the compliance space, the knew right off the bat and then others when I am finding, let me give a quick example, Mike Jacka. He actually did not want to have anything to do with compliance. It was a boss that said you know, you have got some really good -- guess what people skills -- you have got some really good problems solving skills. So he nurtured him over and over and over again and the boss happened to be an internal audit. And my point is, one of the reasons I like this profession is you have to interact with people when you area auditing. People think it is just data, only no. That's just, you know, half of the story. The other half you have to talk to the people and it does change and compliance does change, we are in a global economy and therefore, a country like India, Germany, etc where you are doing business, or your client's doing business, again, they are changing their laws. And so, it is going to be an involving compliance arena that we are working under and so for me, it is always kind of a nice challenge. It is never going to be the same thing over and over and over again. That has been my point on the profession of, if someone had to just call it the compliance arena. And the people part of it too I think I enjoy most as well.

25:53 Sonia Luna

Well this has been a great insightful interview Alison. I am really grateful that you are here with us and as a quick reminder, for those of you who haven't registered yet, you can see Allyson at the conference. Please visit the website, www.complianceethicsinstitute.org. This is Sonia Luna, CEO and Founder of AVIVA Spectrum, signing off!

26:23 Allyson Boulden

Thank you so much Sonia, it was a pleasure talking to you.

26:28 Sonia Luna

Take care Allyson.