Compliance does not come, but is born of you

What were my beginnings like, how did my professional life lead me to land in Compliance? Well, I have believed that Compliance does not come, it is born from you. I don't believe in compliance, I don't believe that it is just a job to move so many emotions, to move positions, to transform a culture of integrity in organisations, I believe that it is not limited to a job, so I have believed that Compliance has been with me all my life. I had the best Compliance Officers, my parents; from them I was able to see what Compliance was, how it was lived, what integrity meant, how to behave well, how to take care of our image, how to be congruent. 

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But Compliance came to me from the university, because I studied at a university with a very North American profile. At the university I had a scholarship, and they asked us to do a type of social work to compensate for this financial aid, and I was assigned to be responsible for monitoring the fulfilment of social service at the university. At this university, social service was not a professional internship, but rather it was to support the community, both in education, to learn to read and write, and depending on the specialisation you had, it was to support the community. 

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From these internships, I learned what an audit was, but above all I learned the importance of telling the truth, the importance of not wanting to go over everyone's head, under the pretext of graduating. Unfortunately, I had to identify cases where they were not doing internships, i.e. supporting the community, but some students had acquaintances who signed the papers for them to pass the process. 

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And who would have thought that these years of practice at university would later become a clear foundation for compliance. I am Compliance, already as a graduate lawyer and I work in organisations, but the funny thing is that I never saw it as a job.

Adriana, as you say, your extensive professional experience has taken you through a long list of multinationals; this is of great added value. One of the large multinationals you worked for is the tobacco giant Philip Morris. How do you approach the management of compliance programmes in industries and sectors where the first point of conflict is perhaps the unhealthiness of a product, and what is your opinion in this regard?

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I was very young at that time, and you know that age is important, it is not the same at 22 as at 40, when you are already asking yourself other concepts and with another level of depth. At that time, I didn't analyse the product and the philosophy, and later I confirmed that I wasn't wrong. What do I mean by this? I think that those of us who do Compliance are dreamers, because there is a degree of idealism that always accompanies us, of wanting everything to be perfect and everything to be clear, everything to be very good. Compliance starts as a quality issue, and quality means congruence and commitment, and it means truth in what you do, no matter whether it is tobacco, medicine or the media.

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What you do has to be the best. And I think I learned that from the great school that Philip Morris was for me, it was my second subject as Compliance. I had already done it before in another company and I was fortunate to learn how a compliance programme was being developed outside the United States. Compliance was born in the United States, the rest of the countries emulated, assimilated and others simply copied what was happening there, without perhaps reaching the fine point or changing the culture. So I learned, in a very short time, that quality is a natural behavioural axis, and I am sure that today it is fundamental to do Compliance. I learned that Compliance means doing things right the first time, mitigating waste, stopping redoing things and having them go wrong again, like that contract that colleagues ask us to sign and we make a mistake in the clause, we make a mistake in the information and we make a mistake again. And that back and forth is too much waste.