How to make your international E&C program resonate locally

What you'll learn on this podcast episode

Ethics and compliance practitioners are often thinking about ways to engage their employees and motivate them to live their values, rather than doing the minimum required by the rules. But how can you make engagement real on a global scale when you’re dealing with a truly global workforce? In this episode of LRN’s Principled Podcast, host Susan Divers discusses how E&C professionals can make their international programs resonate through localization with John Toy, the chief of ethics and sustainability at GlobalFoundries. Listen in as the two talk about John’s approach to this problem, which can be summed up in two words: enterprise engagement. 


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Guest: John Toy


John Toy is the chief ethics and sustainability officer at GlobalFoundries (GF), a global leader in feature-rich semiconductor manufacturing. In this role, John leads the company’s ethics and compliance program, which he designed and implemented, in addition to GF’s environmental, social, and governance (ESG) functions.  Previously, John held various positions in human resource (HR) leadership for the company, including global talent acquisition and global learning and organizational development leader.   

Prior to GF, John was employed by medical device maker Boston Scientific Corporation. His professional experience includes leading all aspects of HR at an ~800 employee operations facility; leading a global initiative to transform HR service delivery to include creation of service support centers in Hungary and Canada; and the creation and leadership of an internal HR Service Excellence function. John also led training and development for Global Operations, where he established the function and an integrated network of training representatives from each of the company’s manufacturing facilities in the US, Costa Rica, Ireland, and the Netherlands. 

Before his corporate roles, John was previously engaged in private legal practice with a focus on labor and employment matters. John has appeared before state and federal courts and several administrative bodies, including the NY Division of Human Rights and the National Labor Relations Board. He is a graduate of Albany Law School of Union University, and of the State University of New York at Binghamton, where he studied Industrial and Labor Relations. 


Host: Susan Divers

Headshot of LRN Principled Podcast host Susan Divers

Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years’ accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Mrs. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative. 

Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics.

Principled Podcast transcription

Intro:  Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change-makers.

Susan Divers: Many ethics and compliance practitioners are lawyers, including myself and our guests today. While it makes sense that people with knowledge of law are common in the E&C field, lawyers as a group tend to favor rules and penalties as the mainstays for ethics and compliance, but are there approaches to E&C that are more effective than this approach? LRN's 2022 program effectiveness report showed that 78% of our respondents worldwide reported that their firms emphasized company values rather than rules and procedures to motivate employees to do the right thing. Of course, you need rules, but values make a much more significant difference in changing behavior. What does that mean in practice? How can E&C professionals engage their employees and motivate them to live up to their values, not just do the minimum required by the rules? Well, hello and welcome to another episode of LRN's Principled podcast. 

I'm your host, Susan Divers, director of thought Leadership, and best practices at LRN. Today, I'm delighted to be joined by John Toy, chief of ethics and sustainability at GlobalFoundries. GlobalFoundries is a global leader in feature-rich semiconductor manufacturing, and John is as mentioned, the chief ethics and sustainability officer. He leads the ethics and compliance program, which he designed and implemented, as well as GlobalFoundaries ESG functions. Previously and somewhat unusually in the E&C community, John has held many positions in the HR function, including for his last company heading up human resources. His thought leadership in this area I think is particularly good in terms of pointing to ways to engage employees. So John, thank you for joining me on today's podcast. As I understand it, your approach to employee engagement and to E&C can be summed up in two words, enterprise engagement. Is that correct? 

John Toy: Yeah, Susan. Hey, thanks very much for having me, and I'm glad to offer my thoughts or my two cents on how things work at GlobalFoundaries, and I do believe a lot of our work and ethics and compliance is about employee engagement across the globe. I think that to me, it was really the foundational piece of how we designed our program here. If you want, I can get into that. Is that okay? 

Susan Divers: Sure. Why don't you start off there and then we'll take the conversation where it goes. 

John Toy: Yeah. Happy to, Susan. As you started the intro, and thank you for the intro for me and my company, I do think context is really important when I think about ethics and compliance and how to make things real. We are a semiconductor chip manufacturer. GlobalFoundaries is the company, and basically, when you think about semiconductor manufacturing, it's very popular right now because the world has run out of chips and how do we get all of our chips? We make a semiconductor chips in the US in Burlington, Vermont, and in East Fishkill, New York and in Malta, New York. We also have a manufacturing facility in Singapore, a large one, several facilities actually, as well as our location in Dresden, Germany. We have support locations throughout the world as well. Bulgaria, India, and China, Taiwan, Austin, Texas, Santa Clara. When I was asked years ago to create the ethics and compliance program for GlobalFoundaries, the first thing that came to my mind was organizational engagement. 

How do we actually get the individuals at all these locations all around the world to be engaged in the work that I was asked to do? I'm working in the corporate office now, but at least in my history, I have worked in some site or operations locations. I designed a program with a partner of mine and we presented it to our leadership and the program really focused around the creation of compliance networks at each of these locations. The compliance network to me is five to seven influential employees who are really a cross-function of the location. They're not all in human resources, they're not all in operations, but they're bits and pieces of finance, global supply management, operations, employee relations, things of that nature. This group of people, it's a hub and spoke model where I'm in the center and the sites are the spokes, and I really look at it as I work for them and they work for me. 

I work for them because they are the ones who are explaining to me what the real issues are at their locations and within their regions. They will come to me with concerns and it might be a little unique to something that's happening in Bangalore, or it might be something that's unique that's happening in Burlington, Vermont. They're telling me what's happening in the real world. Now, I try and address their issues. One example I would use is one of the regions came to me and said, "Look, we're having a lot of issues on the manufacturing floor as it relates to respectful workplace," and that's certainly part of our code of conduct, so I designed a program around respectful workplace and piloted it with that site. We did a couple of pilots and it was to address how people actually treat each other on the manufacturing floor. 

I handed that off to that location to then deploy throughout their site. Six months, nine months later, 2000 people had been through a highly interactive, intensive respectful workplace program. That's an example of how I work for the sites. On the flip side, they work for me too because sometimes I will come up with some ideas about training and I'll need them to help me with training or I will have an investigation that's sensitive, and now, if I get a claim or a whistleblower hotline complaint that's in Dresden, I have a group of people who I can go to to help me navigate the organization onsite and also help steer and guide that investigation. Let me pause. Is that helpful, Susan? 

Susan Divers: Yeah, that's very helpful, John. I'm really struck by how you've built those relationships and how obviously they get stronger over the years the more the two halves work together. I'd like to get into some more examples in a minute, but how did you decide on that approach? Was it your background in human resources or your own experience in the workplace? I'm just curious. 

John Toy: Yeah, I appreciate that question. I love the expression that everybody has a story and I always like to hear about other people's stories, but your story is what brings you to how you actually operate here. For me at least, it started with context. Again, context is important. Let me go back in time a little bit. I am an attorney. I practiced labor and employment law for about five years. At the end of my time with practice, I looked at the attorneys that were 10 years older than I, 15 years older, and I decided I didn't really want their lifestyles, so I decided to move to human resources. My first job in human resources was to lead a manufacturing facility, actually a franchise for a medical device company. It was a great experience where I was able to understand operations, understand research and development, sales organization, and really start to understand all the functions of HR. 

I was asked at that company to lead a global project and it was an outsourcing project for HR services. What we were doing is we were creating service centers in St. John's Canada and Budapest, Hungary. We were upgrading our PeopleSoft, our human capital management system, introducing manager self-service and employee self-service. We were also introducing for the first time a learning management system at the organization. That is a lot of change in about a two-year period. As the leader of that program, I really had a real indoctrination to how to motivate people and how to engage with people around the world because I had to work with a number of individuals who knew that at the end of this outsourcing exercise, they may be losing their jobs. Having them engaged to create global process designs and help set up a service center and things of that nature was a real challenge, but it also informed how to get connected with folks, I call it, in the real world. 

From there, I was asked to lead an operations training and development group, and it was a great job. It was a whiteboard job where the head of operations at this company said, "We're spending a whole bunch of money on training and development. I don't know who's best. I don't know who's worst. Go figure it out." It was an individual contributor role. There was no big team. What I did on that role, that was the first time I introduced the compliance network model. We had I think 12 or 13 manufacturing facilities. I set up training and development networks at each of the facilities so that I could learn them better, they could learn me better, and I could figure out how I could service them. 

That's really what I brought with me to GlobalFoundaries when I started this piece. To me, it's all about engagement, and I like your opening comment, Susan, where you said it's behaviors and values. I hear our values drive behaviors and how do we enable the success of our employees in the ethics space? To me, that's much more powerful than having a pristine code of conduct because in the real world from my perspective, we want to make sure that our employees are open and willing to talk to us and raise concerns and ask the questions while they're in the heat of the moment. I think the background in human resources and all those organizational change and change management experiences, that's what brings the passion for me for this role, because I've often said best part of my job is when someone calls me and they're in a real troubled spot and I can help them navigate that issue. 

Susan Divers: That's terrific, John. I'm really struck by the service orientation that you have, that you're there to help, you're there to serve. You work for your compliance network, they work for you, and that really must be based on trust, and then what you were just talking about too with the employees, building that climate of trust and service rather than being the cop shop I think is really an important point for people to think about in their own programs. Let's talk about some of the key activities that you've undertaken to engage people. Let's get practical, because I know you have some amazing stories and I think those would be great to share. 

John Toy: Sure, happy to. When I think about engagement, well, first off, I think it starts from the tone at the top. I'll go through some of the touchpoints. We have our CEO messaging annually. Our CEO is very supportive of the ethics and compliance program, and actually, as we went through the pandemic, I think we enhanced our messaging because he started doing some weekly and biweekly video messaging, and that was a great opportunity for him to promote the ethics and compliance program. We had one of those videos where I interviewed him and he interviewed me about what kind of concerns people raise and profiled me as someone to come talk to. Not just me, but the ethics and compliance office here, which is a handful of people and all your compliance network members. It was through his voice we were able to communicate about our program. 

Another way is Leading at GF. Leading at GF is a mandatory course for managers and above. It's a two-day course where all managers learn about GlobalFoundaries and how to lead for our organization. Well, I have two and a half hours in that Leading at GF just about ethics, and the ethics is sure it's about the code and some rules, but it's much more about how do we enable the success of our employees. I have a section that I call Why Good People do Bad Things and it's all about the environmental factors. It's funny. I think sometimes managers come into the course and they're ready for a snoozer and we try and keep it lively. I have a punchline in there where I show them things that really have... Not only what's happened out in the world, like negative issues that have happened around the globe, but then I say, "What about these four or five things? Where did they happen?" 

They all pause and then I say, "Well, these all happened right here," and I think everybody sits up a little bit stronger and then says, "Well, wait a second. What's going on?" We talk about the environmental factors that they can influence and create to either enable their employee success or actually hurt it. Now I'm going to just quickly go on and talk about manager on-ramp. Every new manager gets an hour training on ethics and compliance. All new hires go through their annual code of conduct training. For that training, what we do is we change it every year. We try and make it not to check the box. We have videos from our leaders or this year, we had our chief manufacturing officer, he is probably the most visible gentleman aside from the CEO around the globe. He introduced the program, talked about Speak Up and encouraging individuals from Speak Up. 

He's Singaporean and he's based in Singapore, which again, about half of our employees are there, maybe a little less, but it's a big impact to trying to encourage that Speak Up culture. We've had other leaders on video. We have quarterly Fab GM meetings is what we call... Quarterly meetings to cascade messages. We generally have a slide at least three times a year where the leader of the fab, which is our factory, the leader of the fab is actually highlighting the importance of ethics and compliance. What we can drive globally is we do an ethics week where we focus on online games, crosswords, prizes at local sites, things of that nature. Our compliance network is profiled. You do coffee with compliance sessions where we have a little bit of a package that goes out to all the networks and the networks decide how they're actually going to operationalize ethics week. 

That's up to them, but we provide all the information, all the detail, and then their only obligation is that they share with us what their plan is and that we know what's happening when and how do we actually capture the number of contacts and what the substance of the engagement is. Every year, we start with an organizational engagement plan, which is a very formal plan of saying, when are we going to touch the organization and how? It changes during the year because we have different issues that come up or there may be a business issue, so we may move something from September to the next month, but we're also sensitive to what's happening in different regions. We may highlight gifts and entertainment in the summer months in the northeast of the United States because a lot of our vendors will engage in some entertainment activities at that time, but then we'll highlight that same topic in Singapore during Lunar New Year because that's when a lot of vendors will actually give gifts and things of that nature. 

I should mention one more thing before I pause. We do an ethics speaker every year, which I've found it to be really, really positive. It started just at one location, one of our factories where we invited somebody to take an hour out of all the leaders' time to speak about ethics. Over the years, it's now become a global event where all directors and above spend an hour, CEO led, I orchestrate the speakers and all those kinds of things, but CEO led where we have someone come in and start talking about ethics and what happens. The focus areas have been external issues. 

When we went public last year, we had a focus on material, non-public information and insider trading. We've had Speak Up culture. We've had the science of the mind and how individuals think in ethical dilemmas and ethical situations, and it's really that focus that we video that, we then chop up the video and then distribute messages during the course of the year. That's how we touch, but it really starts with the compliance network. They help us build the plan in the beginning of the year, what's happening at your site? We'll do some unique things in regions, but we have real corporate plan on this issue. 

Susan Divers: No, I think it's an excellent example of how you've really gotten your program out of the legal department and into the company. It's really in the drinking water. What's so impressive is you've done it at so many different levels, and an intellectual level with the annual speaker and probably very inspirational, which gets people to really think about topics in depth. The video and the use of repurposing it and sending it out to reinforce key messages and then timing reminders like gifts and entertainment right around the time when they're the most relevant, that's really the opposite of just having a paper program, but tell us a bit more about... You've got such a diverse workforce, Singapore, Dresden, arguably Burlington, Vermont. Now I love Burlington, but it is different. How do you localize your program? I'm sure you do it through your compliance network, but can you give us some examples of how that's worked in practice? 

John Toy: Sure, sure. No, and thanks for that question because I do think that my view of the world is global program is necessary. We need consistent messaging. We need to make sure that everyone's on one page. I've worked in organizations that have been so disparate that it doesn't really work. You need to have the global tone at the top. Here's the global processes, and I should highlight that we have a disclosure process for gifts and entertainment, conflicts of interest, whistleblower hotline, and then also contacting the ethics and compliance office. All of those are global programs. They are in several languages so that we address the language needs of our employees in Germany, but when you call one number, you get one set of answers, you get one set of individuals. It's not just all about being regional. There is a lot of global pieces. 

Actually, before I hit the regional piece, I think of the ethics and compliance office really as a bit of a service center. We have created... We're up to probably 20 SOPs right now, where how we answer questions, and it's an SOP to be rigid, but it's more to enable the success and consistency of our office. I do look at it that we are a service center and there's nothing wrong with that for our employees, but getting to your question about some of the unique natures, just as an example, the network model, we had a speaker once in... One of those ethics speakers. His name was Chris Adkins from the University of Notre Dame. He was a professor of ethics and leadership, and he is a wonderful speaker. He came in and talked about the science of the mind and how people make decisions. 

Boy, we thought it was wonderful. The CEO thought it was wonderful, I thought it was great. Everyone was all jazzed. We put that into our annual code training and I put five, seven minute clip of the video in the training and I sent it out to the network and I said, "What do you all think?" My partners in the US thought it was wonderful, let's get it out there. The folks in Germany said, "This is great content, but not going to work here. You need a German speaker," and the team in Singapore said, "We're begging you not to do this. Please don't deploy this in our neighborhood. It's not going to work," and I think that was a great use of the network where they're saying, "Okay, John, you think this is great, but it's not great." I paused and we changed the training and we made it a little unique that year where we did something in the US but different in Germany and Singapore. 

That's just an example of how you have to listen to the folks to react before you do something that's not going to resonate. Another example I'd use, Susan, is doing the leading with ethics training in Germany all these years, I think ethics is pretty understandable, but in Germany, it's really not. Integrity as a word and as an understanding is much more meaningful. We've changed our ethics program to always associate ethics with integrity because it just helps in the translation, the messaging. Another thing that I would highlight is anonymous reporting, which we talked about in our initial discussion, I know that anonymous reporting is important to say I'd rather not have people report anonymous because we want to make sure that they're open about giving their name, and we don't want them to feel that they must report anonymous. 

That's a common theme I see in ethics and compliance circles, but in the practical matter, we actually encourage anonymous reporting in Singapore because in Singapore, it's a very hierarchical society and it's very difficult for individuals to raise claims about their manager or their supervisor. We felt like we weren't getting enough of an engagement in Singapore, so we've really gone out and even leaders have encouraged anonymous reporting if somebody sees something that is questionable. Yes, it may look poorly on our metrics around what anonymous reporting looks like, but it really meets the needs I think of the region. 

Susan Divers: I'm really struck by how you make an effort to meet people where they are. You don't make the assumption that because it's how we do it in the US, that that resonates in Singapore or Germany. It shows a good deal of respect I think for people. It seems to me that your whole program is really infused and based on values, which is a good illustration of how to really have an effective program. With that in mind, any advice for E&C professionals listening who are grappling with diverse international workplaces? What are the must haves and through the first steps to take if you're going to shift from a predominantly rules-based approach to a values-forward strategy? 

John Toy: I've made a lot of mistakes in my career as you try and learn things. As I look back to that role I was describing before at another employer, the medical device company, the first meeting that I had to do a global process design before we outsourced some of the work, I had a room full... It had to be 20 people. Some from Ireland, some from Costa Rica, some from the US and different parts of the US. I tried to facilitate a discussion around a global process design. I found that the individuals from Ireland weren't saying a word. The folks from Costa Rica weren't engaged, and some of the folks from the US were really dominating the conversation. I had to call a timeout for myself right away to say, "What am I missing? What's going on here?" It was through engaging with some of the individuals on a very personal level as to where they're at with this change that was coming up and how we're actually going to actually manage the change. 

That once I got to know them and understand where they were coming from, that really helped. I had to do this about a dozen times, about a dozen global process designs. Each of the other sessions went much better. What we really did was we took a half a day before we did the global process designs and had us meet as a team beforehand to talk about where everybody was on their personal change curve in this change that the organization was going through. I used that as an analogy because to me, the biggest thing is to listen to folks in the regions and then demonstrate that we're actually going to do something when we listen. I do think that that builds trust. One example I would use would be the one I just talked about where the speaker from the US who I thought was great. 

Well, what was the impact of Singapore saying, "Please don't do this here." Well, it required me to go back to the CEO and say, "This video, which I know you love, is not going to work. We're going to have to delay the rollout of our code of conduct by 30 to 45 days, because I have to rework some things." Then we have to get some translations done in the middle there too because we deploy that training in Mandarin as well. I went and took some heat for missing my deadline, but to have a better result. I really think that the team that I worked with appreciated that. What we're doing is not on balance. It's important for the organization, the foundation of course, but building that trust to say, "I will go and I'll take the hit," for something I thought was a great idea that wasn't, I think that helped. 

The other thing I think, Susan, is again, listening to the individuals. I'm sure everybody who's ever going to listen to this does their own risk assessment, and GlobalFoundaries does our ethics and compliance risk assessment as well. What we do is we have about 35 targeted areas, and we meet with 18, 20 people at corporate and we evaluate the risk areas and it's diverse and it's across the organization. We get an initial risk evaluation done. Then we'll send it out to the sites and we'll have the compliance networks do their own assessment of our work, where we write, where we not write, how did we do, what's unique to Germany, what's unique to Burlington, what's unique to Santa Clara or Singapore or Bangalore? Actually, I don't if I mentioned Sofia, Bulgaria too. 

They'll come back and they'll do their own risk assessment and then we'll set goals for each of the locations that have got half corporate goals and half local goals, and then we evaluate ourselves together. I do think it's about that kind of trust and enabling them to see that as the individual from corporate, I really do want to connect with them, and maybe I'll close with this. I have an expression I joke around a lot about, which is if you've worked in an operations facility, I usually start conversations with new facilities with, "Hey, I'm from corporate, I'm here to help," and then everybody starts laughing and rolling their eyes because when you come from corporate, generally it means, "I got a spreadsheet I need you to do. Can you help me out?" 

If you're in a manufacturing world, in an operations world, their number one priority is making good products. Anything I'm going to ask them to do is going to take them off that path, so we try and break down those barriers and try and enable their success, but I do think listening and reacting and responding to that feedback is the way to go. I got to be honest with you, I really enjoy it. Better part of my job is just to understand how people think in different parts of the world. It's great. 

Susan Divers: Well, I think it's very impressive, and I'm sure it's very effective because you're building trust and respect as the basis for communication. When people raise legitimate issues, you don't brush them off. You obviously take those into account, as you pointed out, even if there is a bit of a cost to it. That's what we want our colleagues in the business world to do. If you're running an E&C program, if they see an issue that concerns them or that needs to get resolved, to stop and resolve it and maybe pivot, even if there is a bit of a cost involved. Again, it's a great example. Well, John, it's been such a pleasure speaking with you on this podcast. I hope you'll come back and speak with us again soon. 

John Toy: Thanks very much, Susan. Thanks, and I appreciate the opportunity to just talk about what we do. Thanks very much. 

Susan Divers: Great. My name is Susan Divers and I want to thank all our listeners for tuning in to the Principled podcast by LRN. 

Outro: We hope you enjoyed this episode. The Principled podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance and global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.

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