Speaking Engagement
“Run Compliance Like the Business,” Steve Grimes Keynotes C-Integrity Hong Kong 2019
Speaking Engagement
“Run Compliance Like the Business,” Steve Grimes Keynotes C-Integrity Hong Kong 2019
May 8, 2019
Integrity is a key principal that organizations around the world embrace, but it can also be a conundrum for executives, general counsel, and compliance officers, who often find themselves struggling with competing priorities, lack of resources, and ever-changing regulatory regimes. A recent speech delivered by Winston Partner and Chair of Asia Litigation practice Steve Grimes, “The Role, Purpose and Perspective: White Collar Defense From the Perspective of an In-House Counsel, the Role We Play as a Defense Lawyer and the Purpose of the Prosecutor,” presented a holistic perspective on corporate compliance and regulatory defense.
During the C-Integrity Symposium 2019, held on May 8-9 in Hong Kong, Steve delivered the keynote speech to over 200 in-house legal, compliance, audit and information security professionals. “There are two ultimate goals for every compliance program—to prevent and deter misconduct and to mitigate the impact of misconduct,” Steve shared based on his experience as a former Chief Compliance Officer. He introduced the core competencies and specific objectives of compliance programs, as well as step-by-step practical guidance on running an effective compliance function “like the business,” using a continuous improvement management framework. He also explained the key considerations from a regulator’s perspective in government investigations—including how to think through a question that companies regularly ask: whether they should self-report potential misconduct. Steve told the audience that he seeks to reframe that question, and instead ask “based on our internal response, how would this look if the government finds out after we made a choice not to self-report?” Steve previously served as an Assistant United States Attorney for the U.S. Department of Justice, assigned to the Public Corruption Section in Chicago. He discussed situations where individuals have clearly violated the law, putting the company itself in the cross-hairs of a government, noting his view that the crucial inquiry is whether the regulator views the crime as having been committed “because of” or “in spite of” the company’s compliance program.
Steve also hosted a workshop focused on data security and trade secret protection during the symposium. “In today’s highly mobile, competitive marketplace in Asia, the issue for companies, no matter size or industry, is becoming when data theft will occur and how damaging it will be rather than if it will occur,” Steve said, highlighting the risks inherent in the modern network economy where vulnerabilities exist along supply chains and all forms of commercial partnerships. He analyzed the trend of trade secret cases, the significantly growing damages, and the courts’ interpretation of trade secret laws, and noted that “numerous cases were dismissed because the victim company failed to take ‘reasonable measures’ to protect their purported trade secrets.” This once again underlines the importance of comprehensive trade secret protection programs. The session concluded with Steve walking the audience through a “Maturity Model” which assesses the sophistication and robustness of trade secret programs along with various main objectives, evaluates risk factors and risk tolerance, and identifies precautionary steps to take to match the company’s risk profile.
Contact Steve for more information about this program. Learn more about Winston’s Compliance Program here.