Using ethics and values to rebuild, not just recover, from corporate crisis

What you'll learn on this podcast episode

Stories of compliance failures aren’t strangers to news outlets or entertainment networks. But while the circumstances can make for great media headlines, what is arguably more interesting is watching how those companies respond. In this episode of the Principled Podcast, host Emily Miner is joined by Carlos Villagrán Muñoz, Gerente de Compliance (Director of Compliance) at CMPC. Listen in as the two discuss how, over the past decade, CMPC has sought to not just recover from a significant compliance failure, but rebuild—stronger—by focusing on ethics, culture, and values.

Principled Podcast Shownotes

  • [2:50] - Carlos briefs listeners on his company, CMPC.
  • [3:53] - Describing the collusion scheme involving CMPC which took place in the early 2000s.
  • [8:03] - The potential root causes which can motivate people to commit fraudulent acts.
  • [14:10] - How has CMPC sought to rebuild stronger in the aftermath of this misconduct case.
  • [16:13] - The role of ethics and compliance at CMPC.
  • [23:38] - Rules vs. values in company culture.
  • [30:25] - The evolving risks at CMPC.

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Guest: Carlos Villagrán Muñoz

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Carlos Villagrán is a Chilean attorney who graduated from the Pontificia Universidad Católica de Chile with a Master of Laws (LLM) degree from Georgetown University (US). He currently serves as Director of Compliance of CMPC, a 100 years old Chilean-based holding, one of the worldwide leading manufacturers of pulp, paper, packaging, personal care, and other forest products. With more than 19,000 employees, CMPC has industrial operations in 8 countries (LatAm) as well as commercial offices in the US, Europe, and China, selling and distributing its products to more than 45 countries around the world.

He has previously served as Compliance Officer for the Chilean operations of Liberty Mutual Insurance and Mitsubishi UFJ Financial Group, as well as Legal Intern at the World Bank’s Integrity Compliance Office.

Host: Emily Miner

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Emily Miner is a Senior Advisor in LRN’s Ethics & Compliance Advisory practice. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN’s ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology.

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.

Emily Miner: In society and the wider business community, we've moved away from the idea that corporate misconduct is caused by bad apples alone. Unethical decisions and actions generally don't take place in a vacuum, but are enabled, facilitated and sometimes demanded. And a variety of factors can be at play. The ignorance of rules and regulations, business strategy, and incentives, or pressure from and the examples set by leaders. Stories of corporate malfeasance aren't strangers to news outlets or entertainment networks. But while the circumstances can make for great media headlines, what is arguably more interesting is watching how those companies respond.

Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Emily Miner, senior ethics and compliance advisor at LRN. Today I'm joined by Carlos Villagrán Muñozn Munoz, Gerente de Compliance at CMPC. CMPC holds the infamous title of being responsible for the largest antitrust violation in Chilean and Peruvian history at the time. But over the past decade, the company has sought to not just recover from the scandal, but rebuild stronger by focusing on ethics, culture, and values. We're going to be unpacking that journey of how CMPC got from there to here and where they continue to go. Carlos, thank you so much for joining me on the Principled Podcast.

Carlos Villagrán Muñoz: Thank you so much, Emily. And thank you, LRN for this great invitation, and for giving me, or for giving our company, CMPC the opportunity to share our journey, the CMPC journey. I honestly believe that our experience can be of great help for other companies, for other compliance teams facing hard times. And then by the way, I'm a huge fan of this series of podcasts so I really hope to rise to the occasion.

Emily Miner: Oh, thanks. That's so great to hear. And I completely agree. I think this story, it contains so much that can be learned for other organizations, both in terms of preventative measures, but also when these types of instances arise as they do, as they can, how to respond. So I'm really excited to have this conversation.

Carlos Villagrán Muñoz: Great.

Emily Miner: So before we jump in, let's set the stage a bit. Can you tell me about CMPC? What do you do? Where do you operate? How many employees do you have?

Carlos Villagrán Muñoz: Absolutely. Sure. So CMPC is a hundred years old Chilean based company. It's a Chilean based holding. It's a very traditional, very respected, very well known company. And one of the worldwide leading manufacturers of pulp, paper, packaging, personal care, and other forest related products. CMPC currently has more than 19,000 employees. We have our operations, industrial operations in eight countries in Latin America. We're a really Latin American company, as well as commercial offices in the US, Europe and China and the company does selling and distribution of each products to more than 45 countries around the world. So we're talking about what we call a multilatina, multinational, Latin American based company.

Emily Miner: Thank you for that context. And so my understanding is that in the early 2000s, one of your divisions was involved in a collusion scheme that lasted for about 10 years before it was discovered and the company self-reported to regulators. Can you tell us a little bit about that collusion scheme and what enabled the situation? Because I think that that's, this is where we get down to the lessons that can be learned and shared for our listeners. So was it a lack of appropriate controls? Were there misaligned incentives, the role of the culture, all of the above? Tell us a little bit about that.

Carlos Villagrán Muñoz: Sure, sure. Emily. So I will take just a few minutes to give a general context of the case. So CMPC created and participating in a cartel. We are talking about collusion with a key competitor to assign market share, to control the prices for the products in a very particular business unit. We're talking about what we call at that time, the tissue business unit, personal care products. Okay. At that time, this subsidiary in Chile and Peru, because the case happening in those two jurisdictions. There were very small subsidiaries at the time, just one or two out of 20 or 30 subsidiaries, heavily focused on retail or mass consumption. So a little bit about the history of the case in June, 2014 the company became aware of an investigation conducted by authority in Peru involving your local tissue operation in Peru.

What the company did was of course, running internal investigation, including all the subsidiaries, just to check if this allegations were true. And if so, if that conduct was also present in other operations. But you know what, nothing was found. But then one year later, the local in Chile, the Chilean Antitrust Authority began their own investigation. And then the company CMPC realized, "Okay, we have a problem here." So the investigation was resumed new interviews with executives, and there you go, the company was able to identify serious antitrust infringement. And they actually occurred from almost 10 years, more than 10 years from the year 2000 to 2011, at least in Chile. So in that moment, the company decided to self-report to the local antitrust prosecutor office giving maximum cooperation to the authority here in Chile and Peru. I want to go into the videos, but you know, the aftermath is that the company CMPC was fine, both in Chile and Peru, we're talking about around $30 million as a global amount.

The company required both entities to implement an antitrust compliance program. That's one of the reason why I joined the company in 2018 as part of that effort. And additionally, I think it's important to mention this as part of the culture that we will discuss later is that the CMPC voluntarily reach an agreement with the national consumer office here in Chile, in order to at least to try to compensate the final consumers. And that agreement was up to 150 million in total, almost around $10 were given to each Chilean citizen by with 18 years old and older. This is the so far first and only case in which a company tries at least to compensate not clients, but the final consumers of the products that were involved in this collusion scheme. So as you can imagine, we're talking case with a huge reputation and impact.

If you check service even today, public opinion service, you will see that people here in Chile, same in Peru, they see collusion as the same type of violence, as other cases such as corruption in politics and the Catholic church abuses. So we're talking about a case that really struck a nerve in Chilean and Peruvian society and the consequences, the reputational consequences are still present today. So let's go immediately to your question, Emily. As you mentioned, I do not believe in bad apples theory because you never perceived yourself as a bad apple. And in this case, of course, we're talking about a 10 years collusion, right? But at the beginning, they were not bad apples. You know what they say? And I like this phrase I saw in one of the seminars some months ago, people do not wake up in the morning with intention to ignore the law or to behave unethically.

Usually, you see that kind of behavior because they are competing objectives, lack of awareness, people neither knew the risks. They were not properly trained. They were the influence of context, the expansion, the growth. There are new competitors. We are under a lot of pressure. So we have to be mindful that these guys, especially at the beginning of the collusion of the cartel scheme, they were not fully aware of what they were doing by the end of course, of the last of those 10 years. Of course, they were aware, but at the beginning, that was not exactly clear. What we saw when I joined the company and we reviewed the case again, with a different optics, not in terms of investigation, but trying to understand the root cause we identify what we call a cultural fracture.

There was no one company. CMPC were many companies. The holding head office had no visibility of a small subsidiaries, such as a tissue in Chile and Brazil. There was a lot of subcultures, different silos, many different cultures. The company was growing. Still it is of course. And the main focus was on the machines, the operation, the technique, but without proper corporate governance. It was way too vertical. Lack of accountability, lack of awareness, no speak up culture at all. Remember what I said before during the first investigation made by the company, the executive didn't mention this. The company was not able to get the information from the executives. So there was no speak up culture. If you check the declaration, the statements made by these employees who were involved in the cartel, and this is public information, by the way. Many of they say, "You know, I thought it was normal."

Another issue with, I identify, what about the compliance program? What about internal controls? Well, the company have in appearance at a formal level, some sort of a checklist compliance on the paper. We had a code of ethics, conduct, hotlines, policies and procedures, occasional training, but no risk assessment, no contingency evaluation. There was not a real compliance program to impact in the behavior of employees. You see motivation, the context, the practices that were not aligned, there was a broken system of shared values.

If you ask at that time, people working for CMPC, they will say, "Our main internal core value is that we trust each other. We trust and honor our world," which is good. It's perfect. But in this case, that main core value was distorted by these subcultures, by these silos, by this alignment between motivation, objectives, the context, the strategy, the standard and the practices. I hope to answer your question, but this question that is part of the DOJ compliance program evaluation guideline is have they, the managers, persisted in their commitment with ethics and compliance in the face of competing interests or business objectives? Well, in this case, the answer is no. When these guys, they have different objectives, very aggressive. They stand by those objectives instead of their E&C commitment.

Emily Miner: As I'm listening to you talk and describe the situation. I'm seeing so many parallels to other really well known cases where a company might have... You talked about having a hotline and training and policies. So having those standard or typical elements of an ethics and compliance program. Obviously we need them, but it's not enough to just rely on those alone. Because the culture of the organization, the example set by and direction set by leadership, the role of values. Those are all arguably perhaps even more important than having the code, the policies, the hotline, the training, but of course in truth, we need both. And so I'm just, I'm seeing those parallels to some of the really big name cases that actually are now, even on Netflix. There's a documentary of sorts about Boeing.

There's one of Theranos, both examples of companies where they had those program elements in place, but the culture and the leadership were not promoting the quote-unquote right thing to do. And in fact when you shared a little bit with me earlier about how this case unfolded within CMPC and how it evolved from the beginning where it was seen more like a business strategy, and then how it evolved into very kind of obviously criminal activity of prepaid cell phones and throwing laptops into the river to destroy evidence and things that you see in movies, but were happening in real life.

Carlos Villagrán Muñoz: Absolutely. You mentioned those two cases, the Theranos case, the Boeing case. It's amazing to see that even if you are talking about different companies, industries, and countries, the root cause for compliance, ethics, and compliance failures are quite similar. You can find similar root causes, even though cases are so, so different.

Emily Miner: Absolutely. So you and CMPC have been really open about this scandal, publicly as well as internally and really using it as a learning experience for the organization. How has CMPC sought to rebuild stronger from this very large case of misconduct and reputational damage in the community, the violation of trust, that sort of those? How have you sought to recover from that? And specifically, you talked about how one of the elements was building out a more formal ethics and compliance program. So what has been the role of your compliance department and the integrity program as part of that recovery process?

Carlos Villagrán Muñoz: Sure. On one side, we have the company being very transparent with the case, as you mentioned, said disclosing, collaboration with authorities, this voluntary compensation to our consumers, just to mention a couple of action. At that time, the chairman of the company, some board members, the CEO, main senior managers, they visit all mills, plants and offices to explain the case. So transparency and full collaboration was part of the narrative from the beginning. We fail. We are sorry. We want to do the right thing. This is a painful lesson but we want to be transparent about it. So then I can mention going, trying to go to the E&C program. In 2016, the company decided to do a complete overhaul of its corporate governance structure, new business units, corporate teams, three lines of defense, new board members, new technology, new teams, internal audit, legal, risk management, HR, sustainability, compliance.

This was a really, this crisis was taken from a holistic perspective. Not just trying to solve an antitrust issue. It was not about antitrust by the way, which can be sometimes more technical infringement, but it was about culture. And the company understood that from the beginning. Now, what about the role of ethics and compliance? When I joined the company, my boss, the board, the ethics and compliance committee, they told me, "We want ethics and compliance to be a tool to change and to manage our culture. We want to change behavior." This was awesome because Emily, there is a temptation to create a very formal checklists on the paper compliance program. And there are so many standards and good practices on benchmark outside. It's easy to create a compliance, a formal, basic compliance program, but this guy is in CMPC.

That is one of the reasons why I joined the company. They were talking about behavior. They were talking about culture and they were talking, maybe we won't be able to do everything we want to do in terms of ethics and compliance, but let's be real. Let's be consistent. Let's be serious. Our first job was to work in an initial E&C strategy for the next three years, what we call the integrity and compliance program, integrity, more focus on values and compliance on rules, on the law, right? And of course, we're addressing the typical dimension of every compliance program prevention, detection, response, focusing on anticorruption, antitrust, data privacy, anti money laundering sanctions, trade control, et cetera. It was a very basic, but a strategy, I'm not saying easy, but basic in terms of very clear strategy. And you have to remember CMPC is, and at that time still is a very traditional company.

So we had to work with the CMPC team. We had to do a lot of hearing, talking, listening, trying to integrate these efforts, trying to explain what compliance and ethics meant and what it didn't meant at the same time. And our first approach. I think that we can talk about this later was more focused on the rules, rather on the values. We created what we call integrity policy which provides a framework of dos and don'ts in different matters and activities with a very practical guidelines, a very basic and easy to understand framework and policy and procedures. Our people, our employees were ashamed. They were afraid. We thought at that time that the company was not prepared yet to talk about values. They wanted that immediate response. They wanted to go back to their works, to their jobs, and feel safe and have very clear rules of what they can or cannot do.

So our main focus was mostly rules. Dos and don'ts are very clear and easy to understand message. Sure values were involved, but again, more focus on rules. And I want to make a short comment here, Emily. I think that compliance, ethics, and compliance is mostly about timing. When you are able to work on a strategy for a company, you have to be mindful that companies, and as any person we evolve, we change with time. So our messages have to change, have to also to evolve. Maybe if we took a different approach four years ago, talking about values that in some cases can be more hard to understand from the... Yeah, I mean, in some cases, maybe the result will have been different. We decided to go with rules just to be able to provide a more clear message. We stressed the importance of a speak-up culture.

That was like the second main objective we were asked to work on. We have a complete overhaul of the hotline system, the report investigation process, the management. We focus our attention on root cause analysis, remediation, communication campaigns on transparency as well, trying to show our employees that the hotline worked, that it was useful that it was an additional tool they could use. Just to give you just a very small example from 2018 to 2021, we're getting almost like three times, even four times more reports through the hotlines. Now that doesn't says a lot, but it really, it is one thing that this figure, this number shows is that people know about the hotline and they are willing to use it.

Emily Miner: Absolutely. Sorry, interrupted. But I feel like it's so often there's the question of if our hotline reports are increasing, is that a good thing or a bad thing? And people have differing opinions, but I generally tend to believe that that's a good thing, because it means that people, as you said, they know it exists. They feel safe using it and you can't respond to what you don't know.

Carlos Villagrán Muñoz: No, absolutely. That's a good sign that at least you are, that they trust the hotline. They know that the hotline is there. And just to close the answer and the third focus was leadership or leaders. We realized again, CMPC traditional very vertical and in somehow paternalistic company. So we use that in our favor. We saw the antitrust infringement case that the senior management example, their words, their message really shaped the culture of their teams immediately very fast, very aggressive in a very aggressive way. So we focus on leaders. We remind them that actually they manage three... Let me put it this way, three main gears or elements to shape behavior. There's the one who set motivations, the objectives, expectation, organizational justice.

There's the one who set the strategy. They, that the strategy business strategy that answers to the context. They do risk management. They do business decisions every day, right? And finally they are the owners of the processes. And therefore they're the owners of the standard and practices that regulate how those processes are done. So we start working with the leaders, telling them these three nerves that you are the owner of can immediately generate a response from employees, can immediately affect how they conduct themselves. So be careful when you push those buttons. And at the same time, we provided very practical examples of how to push those buttons, to move those gears in an ethical way. In order to answer, again, an additional DOJ question. You know this question. How have senior leaders through their words and action, encourage or discourage compliance?

We use that question in all our leadership trainings, and we ask our managers, let's put it in this scenario. The regulators, the police is here. The DOJ is here, right? And they will ask you this. They won't ask you about policies and procedures, controls. No, they will ask you, "How do you encourage or discourage compliance through your words and action." And then we take it from there. And we explain how those words, and with very practical examples, we start providing more tools for the toolbox so they can use the proper words and do the proper actions in order to change behavior. Again Emily, this has been quite an adventure, a journey. We could be talking several hours about this, but this has been a little bit how we have been facing this challenge in CMPC.

Emily Miner: Yeah. And you talked about how programs like people evolve and how immediately after the case was uncovered and being investigated and the fines and all of that. So in the immediate aftermath, the organization chose to focus more heavily on the rules and the dos and don'ts, but I also understand that now you are in the process of shifting the emphasis from rules to values. Now that there's this solid foundation where everyone understands those dos and don'ts moving, expanding, evolving to a greater understanding or appreciation for the values or the shoulds or shouldn'ts. Can you talk a little bit about that evolution and what that looks like at CMPC?

Carlos Villagrán Muñoz: Absolutely. Yeah. We began focusing our attention on rules, but of course, as you know, I remember this LRN season six podcasts between you and Susan Divers, rules are good, battles are better. That very powerful statement. Rules are good. You need rules. You need to update those rules, but values can really guide behavior and shape culture. So what are we doing today in CMPC? As I mentioned before, we set our first strategy in 2018, and now we're in a very critical moment. We are updating our ethics and compliance strategy and the core or the main aspect we want to change or to evolve to it's shaping from rules to values. That's what we're doing today. It's not that we're going to leave rules aside, but we believe that especially during the last times that we are facing very complicated context. We have war, we had COVID, we have increasing pressure from the markets we realize.

And I think that COVID was a very good example, that you can have your best rules, your best program, but facing those changes in the context, in environment. They're so serious and so aggressive. There are no rules that actually can support that impact from those changes. So we need something else that allow us to have one comprehensive ethics and compliance program that can support, that can be there to provide continuous support to the business when there are changes. So now we have a well documented ethics and compliance program. We are trying to shift our attention to values. And I think we are ready to talk about values. Again, this is a lot about timing. Four years later, we are in a very different company. New people has joined the company, corporate structure, new businesses.

There are new narratives. There are new messages going around, innovation, human rights, diversity and inclusion. We are ready to go back to our values and we are ready not only to talk about values. Let's remember we had that cultural fracture. So what we want to do and we're in working right now is to redefine our values. And this is an ongoing process. It will take some time. It's not about compliance department. It involves HR, sustainability, the business itself. This is a collective efforts. And then what we want to do as one team, one company is to update our values at least from a visual side. We are working on different assessments, ethical cultural assessments, surveys. We just work on a program assessment. On a starting point, we want to see what we have been done so far and how to redefine our strategy, because we want, again, a new narrative, a new message with substantial involvement from the board as in the management.

I think that's very important. When you talk about ethics and compliance from a rules perspective, people tend to see that as a legal issue. So one of the things we want to fix is when talking about values, we're not talking about legal matters. We're talking about conduct. We're talking about behavior and therefore the senior management and the leaders of the company, regardless of their position, we have a lot of leaders in different areas and units. We charge with their example, shape and change the behavior. We want them on board of this effort. And that's why we're creating ad-hoc committees. We are opening our evaluation. We are, again, transparency. We are opening our assessments. We are trying to get more people involved to enhance the conversation. Now we're talking about human rights, diversity, and inclusion again.

And that's part of, again, not only, we're not talking about changing the code of conduct and in a word file, okay. Let's share it between three people with some changes and that's it. For us, the final result is important but most important than that is the role. It's the work... We want to do this work with all the employees. So we want to inspire. I think that's something you Emily and Susan said in this season six podcast episode. We want to inspire our employees. Our employees want to be inspired as well, and we believe that values can help a lot. And again, just to close this answer is that Susan said it better than I can do it.

Rules are the skeleton. We need to keep working on rules. We have a strong team performing day to day activities to verify that those rules are observed, but values are the blood and the heart. And I think that now we are in a good position. People who are listening. We have their attention after three or four years of hard work, and now it's time for them to help us to help the rest of the company to again, reevaluate, and update our values. And then all the ethics and compliance program becomes, or keeps being a huge to a substantial tool, a great asset for that goal.

Emily Miner: Yeah. It's about operationalizing ethics and compliance, right? Such a great analogy of rules being the skeleton, but then that's the scaffolding, but the conversations, opening up the conversations... You talked about, not just the end, but the process of how we get there, engaging leaders at all levels, engaging employees, seeking that input, getting ethics and compliance as a habit, as part of the daily [inaudible 00:30:18] rather than something that you do once a quarter when you have to take training or something.

So I want to close by continuing on this topic of evolution and talking about your risks and how your risks are evolving. Of course, they are as like with any organization, for example, I know that you are expanding your operations in Latin America. So there's an expression like driving the car while changing the wheels. How are you thinking about... You're doing so much when it comes to your ethics and integrity program and the organization more broadly. So while you're doing that, how are you also thinking about futureproofing, if you will, against new or changing risks, as you're building out your function and being intentional about shaping your ethical culture?

Carlos Villagrán Muñoz: Absolutely. As you mentioned, Emily, the company keeps growing. We are very recently the company acquired some additional operations in Brazil and Mexico, just to mention a couple of high risk jurisdiction, right? And we have to be mindful that one of the reason behind this cultural fracture was that the company allows subcultures and silos to exist in different countries and business units. So when you said about, you talk about futureproofing, and what about the change in risks? We cannot work on that particular matter without remembering that we have to be very careful that our efforts do not create or foster silos or subcultures, and a key component of E&C efforts is to be simple, to be consistent, and to have one solid and simple compliance program for everywhere. It doesn't matter if you make business here and there, but in order to get there.

And this is part of the answer to your question. We are working on a very extensive risk assessment actions. We are enhancing and changing our methodology of risk assessment. Risk assessment it's the best tool, of course. And it's a key component of every compliance program. It's important to, from time to time to review your methodology. Why are you doing risk assessment? What are the output? What is the business getting from this risk assessment? Are you doing this just to comply with general guidelines of how to manage and to build a compliance program, or do you really want to get something out of that? What about the technology that can helps you to provide in a more easier and clear way the results of that risk assessment? So we need to keep our radar updated. As part of my team, I have a couple of my team members who are focusing mostly on risk assessment which is a continuous process.

And by changing the methodology, we want to train the business to identify the risks. This is not a...Again, we want to avoid the business, seeing compliance at this matter as a compliance matter, risk management risk assessment is a key component of our compliance for insurer. But that's how we can futureproof against new changing cultures, because we will be able to identify trends, new risks and to respond appropriately. COVID was a good example that risk management, risk assessment tools have to be continuously reviewed. We're working on updating and simplify on our ethics and compliance program. There is a corporate initiative called one team one company. Again, as you can see, the companies are aware that fostering silos and subcultures really can expose us to serious dangers and risks. So the E&C program is part of the one team, one company initiative.

We are creating subcommittees, ethics and compliance committee to get the business on a... engage and involve adding key partners from each business. At the beginning, especially during the first years, it was more of an internal job. It was between a couple of internal areas, but now we want to enhance our communication with the business, the supply chain teams, the procurement teams, not just about talking and listening, but trying from the compliance team to provide key information to them. And again, I'm thinking about your question. They are the ones who are the risk takers.

They are the one who make the decisions. So we as a compliance team, we have to help them to have all the risk on the radars to have information on how to manage those risks, because unfortunately we cannot, and we should not exclude all the risk from our business. But we have to be able to inform and to train our people, not about dos and don'ts, but about trying to install, to implement, to give them the capacity to identify those risk to be part of the program. Just to finish the answer we're working of continuous evaluation effectiveness in depth reviews. We have identified high risk jurisdictions, such as Mexico and Brazil, that will require something else than just the basic E&C compliance program.

We are aware that these jurisdictions expose the company in a bigger way. So we have as a team to work appropriately. The board and senior management will continue to be involved. And the hotline this project here, actually, Emily we're not there yet, but our idea is to shift the hotline concept to a help line concept. That's not just changing the name of our website. It's way more than that. And that something that we will require again, talking about values, talking about, it's not about being a cop. It's about being the coach. That's on our radar right now, very exciting times. We're heading to the next three years of our a E&C strategy. And of course, we look forward to move towards values and be prepared for the next risks that can appear or evolve in all the countries in which we make businesses.

Emily Miner: Carlos, thank you so much. There's so much more that we could talk about, but we are out of time for today. This has been I just... Really big thanks for sharing this journey. It can be hard to talk about things that we wish hadn't happened, but I so appreciate the perspective that you and the organization and your leadership have taken on how this is a tool. This is a learning experience. And using that really keeping it front and center as you go forward in so much of your business operations, not just ethics and compliance. So thank you so much for sharing some of those details with us, and I'm sure it's been really valuable to all of our listeners.

Carlos Villagrán Muñoz: Thank you, Emily. Thank you all again for this invitation and for giving us the opportunity to, as you said, to share our experience on our journey. So I really hope this conversation can help other companies, other compliance teams.

Emily Miner: Yeah. Well, my name is Emily Miner, and I want to thank you all for listening to the Principle Podcast by LRN.

Outro: We hope you enjoyed this episode. The Principle Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations, by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at lrn.com 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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