Culture & Compliance Chronicles: The Power of Business Compliance Ambassadors with Alexandra Belmonte

At a glance: Click the links below to advance directly to the corresponding sections of the transcript:

• [1:05] Introduction and Rapid-Fire Ice Breaker Questions
• [5:50] Defining the Business Compliance Ambassador (BCA) Program
• [10:25] Tips for Setting Up a Compliance Ambassador Program
• [14:15] Capturing Management’s Attention and Measuring Success
• [19:55] The Right Mix of Ambassador ‘Voices’ and How to Grow Your Network
• [22:50] Concluding Discussion and Key Takeaways

Amanda Raad: Welcome back to the Culture & Compliance Chronicles, the podcast that gives you new perspectives on legal, compliance and regulatory challenges faced by organizations and individuals worldwide. The clue’s in the title—culture is at the heart of everything. It’s the endlessly shifting patterns that govern our environment and behaviors. The magic is in amplifying certain patterns and dampening others. Let’s see if we can pique your curiosity, get you to challenge some of your perceptions and give you space to think differently about some of your own challenges. I’m Amanda Raad, and I’m joined today by Richard Bistrong.

Richard Bistrong: Hi, Amanda. Super excited about today’s episode.

Amanda Raad: I’m super excited too, Richard. But first, just to quickly sum up our last episode, Megan Reitz helped us to explore speaking up and listening up, and how being intentionally present can help us unleash creativity and a psychologically safe workplace. What do we have in store for us today, Richard?

[1:05] Introduction and Rapid-Fire Ice Breaker Questions

Richard Bistrong: Amanda, I am really excited because I’m introducing Alexandra Belmonte. Alexandra is the chief compliance officer of A.P. Moller - Maersk, based in one of my favorite cities, Copenhagen. Alexandra has been in the A.P. Moller - Maersk organization for 10 years, and prior to that, she was a solicitor based in Singapore. I have had the pleasure of working with Alexandra, and she is one of the leading global voices when it comes to anti-corruption, particularly in the maritime section, and is a very active member of the Maritime Anti-Corruption Network among other compliance associations.

Amanda Raad: Welcome, Alexandra. Before we turn into the discussion, we want to get to know you better, so let’s kick off with a rapid-fire round. First, can you give us three things that we should know about you?

Alexandra Belmonte: Thank you for your very kind introduction. I think the three things that makes me get out of bed in the morning to do what I’m doing, save for my family, it’s people, it’s global dimensions, and it’s that it is difficult, what we do. Going back to people—it’s the people that make all the difference. And as you said in the introduction, culture is about people. It’s the people that make the culture, so I think that makes all the difference. If you look at corruption, which we’re talking about here, in compliance programs, it is very similar to organized crime. You can see how it goes through societies, from low levels up to the governments at the top, so you need to fight it collectively. In order to do that, you need to bring people together, so that’s why people are so important. The global dimension, that’s also very personal, because as a child, I loved to travel. That’s why I’m also in this industry, which is global logistics and shipping, so I get to live my childhood dream every day with the global interactions I have in my work. I think the final point: it’s difficult. What we do is really challenging, and it is difficult because you depend on people, rule of law, politics, trade and societies, and if you look at the global geopolitics at the moment, it’s a very challenging and exciting time. One would have thought that doing the right thing is so easy, but it turns out to be really, really difficult, because there are lots of competing interests. It is challenging—you need to put yourself in uncomfortable situations and have difficult conversations. Then, you grow because you have to challenge your own biases—we do all have them, even if we don’t think so—and look at things from an open mind, being open to new cultures and ways of doing things.

Amanda Raad: I love leaning into the difficult and looking for the opportunities in that—I think that’s great. Now, on to one thing that you are curious about.

Alexandra Belmonte: Curious and scared—and that’s the future. As I mentioned, we live in incredible, exciting times, but also, a challenging time. I think the world that we grew up in is rapidly changing and may look very different tomorrow. And I think that’s exciting, because it comes with lots of opportunities, but it’s also very scary, because I think we all agree we’re seeing patterns that it’s not moving in the right direction. For example, the Corruption Perception Index has got bad scores year on year, and I think what we see in the political arena is also a bit concerning. So, I’m very curious on how we will shape the future and the good forces in people. I think our positions, working in compliance, working for the right culture, becomes even more important in these times.

Amanda Raad: What’s the last thing that surprised you?

Alexandra Belmonte: My children, earlier this week, actually got me a proper birthday gift—it was just the best gift ever. But if we look at this from a professional point of view, it’s coming back to the U.S. administration, that they are pausing almost all spend on aid and relief. I do find that very surprising, because that’s really impacting the minorities and the poorest people in the world.

Richard Bistrong: Great points. I think we’ll stay with that wonderful birthday gift on a positive note. Now, Alexandra, when we last worked together, it was during a virtual gathering of your business compliance ambassadors, otherwise known as your “BCAs.” Perhaps you can share with us a bit about the role of the BCAs at A.P. Moller - Maersk, starting at why you thought it was necessary to have a network of BCAs.

[5:50] Defining the Business Compliance Ambassador (BCA) Program

Alexandra Belmonte: Our BCA program is the crown jewel in our compliance program. I think that’s what is really impressing our external stakeholders such as customers, financial investors and regulators as well. It’s something we really highlight as a differentiator that, “We have this BCA program to help us with compliance initiatives.” Today, they are our voice on the ground, and they have easy access to local leadership, area leadership, and the regional leaders as well as their frontline, so they’re working as a translator between us sitting in center or HQ and with the local entities in the frontline, in many cases. So, they help us in gathering the intelligence of opportunities but also the risks. They have been very good at finding the different patterns and risks so we can act on them in a timely manner. Coming back to one of your comments, Richard—that early connection—that if you have a connection before things go wrong, it’s much easier for people to pick up the phone before it’s too late, and then you can actually do something about that. That’s one of the key purposes of our BCA compliance program. But I would want to highlight they’re not compliance officers, so they’re not advising on compliance—they’re merely acting as the facilitators, looping in the compliance team at Maersk.

Richard Bistrong: Alexandra, can we wind back a little bit? For a lot of our listeners today who would like to have a BCA network, maybe we can talk about what even made you think that a BCA network was needed. For example, was there a gap in your messaging or initiatives?

Alexandra Belmonte: We’re such a big organization now with 100,000 employees in 130 countries, so they help us, being the people on the ground. But if we take a step back, if you look at the industry we’re in, we are logistics, shipping and port operations. Those are very prone to corruption risks because there’s lots of touchpoints with government officials in various stages. It’s also crucial for countries as well as customers because it’s supply chain, so it’s opening up a lot of risk in transactions prone to corruption. I think for the shipping logistics, we’re talking more about facilitation payments, the small amounts to get things done a bit quicker. When we look at our port operations, the terminals, the corruption risk increases, because there we’re talking about long-term investments, winning concessions and extending concessions, so it presents a different risk but one that is very real to us. To add to that, we have the Corruption Perception Index—of course, we are in many countries that have a quite poor scoring on that perception index, so it’s quite a tough environment.

Then, we do a risk assessment every second year on our entities and functions. We’ve got quite a lot of high-risk entities due to the environment and the services we’ve provided, and we did not have the manpower to address it all. So, that’s how the BCA program came about, that, “How can we support locally, on an area level and regional level, without getting more resources to the compliance team?” Looking at the risk, that did not make sense, because they don’t spend full time on compliance, but they need to be those facilitators, so we set up the compliance program addressing the highest risk based on the risk assessment. When we rolled the dice, it was 30 entities, so 30 BCAs. We have since grown, so now, we have over 70, and they are in high demand. Culture is also about change management, that, “How do you get traction?” So, we’ve found support from senior management and executive leaders. Not all of them were fully onboard at first—you need to find the strong voice and then work with that strong voice to amplify it, and then when you have critical mass, it becomes much easier. I think it’s also setting the tone from the top and the expectations. We have our COO as well as our chief corporate affairs officer, which is an ELT member, and that’s where we report into as co-sponsors for the program.

[10:25] Tips for Setting Up a Compliance Ambassador Program

Amanda Raad: Seems like you have already taken this to a great start when you say growing from 30 to over 70 BCAs—that’s huge growth. And you have over 100,000 employees and operate in 130 countries, so clearly, an extremely global reach. Can you just give us some more tips and walk us through how you took this idea and turned it into the great success that it’s become? All of the clients that I work with at so many organizations would really love to have this network, but they have a really hard time knowing where to start, and so, just some practical tips that you might share for things to watch out for.

Alexandra Belmonte: I believe there are a few things one should focus on. I think for the BCAs, you should appoint rising stars in the organization. So, we made it very clear—if you’re in compliance, insurance or legal, then you’re going to qualify. We want someone from the business—say it’s operations or finance, for example—who is up and coming, who is recognized by the managers as having great potential. Then, it’s also important that they feel proud of the appointment, so that they feel, “Yes, this is something I want to do because it aligns with my values.” And also, that their immediate manager and the local area/regional manager recognizes that, so they’re also proud for the BCA appointment, because then you set the BCA up for a much more successful journey as well as the rollout of the compliance program. So, that we have been very clear with, and that’s also why we got the CEO and the chief corporate affairs officers to promote or sponsor the program, so they feel, “This is something top management takes very seriously,” and setting that tone from the top.

Then, I think you need to start small. We started with a risk assessment focusing on our key risks, and finding champions in the business that we could then leverage to get the buy-in for the BCA program, and then roll it out and get that momentum. It doesn’t cost the entity anything other than that the BCA needs to spend 12 hours approximately every month, but it is added on top of the daily activities, so they, of course, need that support from the management that they get the time out to do this. And then, we try to meet in person every second year, depending on budgets—it’s a small investment, and they need to get that support. As I said, it’s about the change management, so once you have those champions and start rolling it out, then the word will spread, and you should use those facilitators, and then it will grow.

We have got requests that we should have BCAs in every entity and function, and I’ve had said, “No, we can’t manage that big of a program—not yet.” We’re trying to grow it organically. What we have seen, which we take as evidence that this is successful, is that the entities that had been high risk but then become medium risk want to retain the BCAs. So, where we can handle it, we will say, “Yes,” but having it for all our entities, we’re not ready for that. That’s the carrot approach. You also have the stick approach. If you do have an internal audit function and they do an audit on your compliance program, you can actually work with them to say, “We think this will be good. Couldn’t you include this as an audit finding, to establish a BCA program?” If you do that, it will, of course, help you, but you may not get the buy-in you want or it would take longer because, I think, when the business feels like they own the initiative, then it’s much easier to get traction instead of coming with the stick and say, “You have to do this.”

[14:15] Capturing Management’s Attention and Measuring Success

Amanda Raad: The co-sponsorship at the top management level seems critically important, to me, and sounds like something you had really great success with. I hear people talk a lot about, “How do you make this a high enough priority to catch top management’s attention, given everything that’s going on within an organization of this size?” Anything you could say there just about how you actually got to launch with top management? What really drove that early engagement?

Alexandra Belmonte: I think timing is critical, so you need to find the right timing. When we got the BCA program up and running, we had a lot talking for ourselves—ESG was coming in; there was a lot of focus on sustainability, compliance and anti-corruption—so, that made it a much easier sell. But coming back to change management, we started with planting a seed and being quite strategic on how we then went about it to get to that “Yes.” Our former CEO signed off on this, and then, when we had our new CEO, he just took over the sponsorship. And what I felt was very satisfying was that there was no question about it—it was like, “Of course, we should continue doing this.” But I think it goes back to starting small, planting that seed, and working your way up.

Amanda Raad: You talked a little bit about some of the measurements of effectiveness, perhaps being just the plain growth, or businesses asking to have representation or risk ratings changing. Are there any other metrics, or how have you thought about measuring that this is working and should be something that you continue to prioritize and put resources into?

Alexandra Belmonte: It was put in place as a mitigating risk factor based on the risk assessment, and then it continued and grew. We have moved away from having the BCAs being our ears and eyes on the ground to becoming our voice, so we try to make it engaging for them and that they feel they have access to center and HQ. We then get their local intelligence, so they feel that they’re also getting something out of it and not just us on the receiving end. Another way we’re looking at it is that we get involved early in opportunities that have a compliance risk to it or they will flag a compliance risk transaction. They are an anti-corruption mitigating risk factor, but they’re also helping us with the other compliance topics such as data privacy, competition law, sanctions and export controls. And now, with the big influx of sanctions and export controls, they actually flag those transactions that have allowed us to look into them even before we flag them in the systems. I think that, for us, is a measure of the effectiveness, that they’re really adding value to the organization and the compliance team, of course.

Richard Bistrong: Alexandra, I really like the way you helped to unpack that so it doesn’t sound as daunting as it might appear, which is the starting small and finding your rising stars or your corporate social media influencers. I love the way that you then overlay that with your risk assessment so you’re not only starting small, but you’re starting smart, like, “Who is going to be your first group of BCAs, and where are they going to have the most impact to drive that change management?” I think that is just brilliant. If you had to think about the top, let’s say, three roles that BCAs can bring in value to an organization—driving change management is one that you’ve already mentioned—what might some others be?

Alexandra Belmonte: First, they are in the field, so they can bring a different perspective to the compliance and the business risk. I think this is in more than one sense, one being that they see what’s happening day to day, and also, compliance is not part of the general portfolio, so they will look at it with fresh eyes while we’re looking at compliance risk on a daily basis. So, I think they bring that different perspective, and then, we can implement that feedback into a compliance program to make it more fit for purpose and also allow it to be more risk-based. We have had a situation where we come up with a nice policy and a process, are about to roll it out, and then they say, “No, no, no. Hold your horses. This is how it is being managed in this transaction,” for example, and then we need to take that feedback and adopt a little bit or adapt a bit.

Another one which we have touched on is the link between the management locally, area, and regional level and HQ, that they have easy access so they also can get recognized and can be put forward for other positions, but also, bring our compliance initiatives or if we need to have a difficult conversation to enable that. Of course, it also gives them access to center and HQ and gives that visibility, so serving as that link. Then, I think, for myself, it’s the inspiration, coming back with this and looking at things with fresh eyes. They say, “Why haven’t you done this?” You mentioned media. They come up with lots of inspiring initiatives where we had a speak-up campaign, no retaliation. We had customer panel discussions where our BCAs in a few countries played a critical part bringing that together because they had that customer relationship and connected us. So, they do give us lots of inspiration, which is very refreshing.

[19:55] The Right Mix of Ambassador ‘Voices’ and How to Grow Your Network

Richard Bistrong: It’s always wonderful to have refreshing, inspiring conversations in an organization. So often, the framing is around controls. I love what we’re starting to frame around inspiration. Speaking about inspiration, Alexandra, I know that your BCAs (and when we had our virtual meeting together), they’re from different roles, regions, and backgrounds—it was such an exciting group. Again, if someone’s starting small and smart, are there a few roles and regions, or a few avatars, so to speak, that you’ve found particularly resonating in your BCA network?

Alexandra Belmonte: Yes, definitely. As you mentioned, the BCAs really show true diversity, because you have all backgrounds, all regions, and different genders, so it’s a truly amazing group. I wouldn’t say any region’s particularly standardized—all regions have their differences—but I think it’s actually more down to the personality. So, what we can see is that some BCAs are more active than others, and they will actively seek opportunities, they will actively raise risk, and they will come with initiatives—they’ll say, “Can’t we do this? Can’t we do that?” Sometimes, we have to actually ask them to slow down because we don’t have the time to keep up with them. I would say we’ve seen it in all regions. It’s more down to the personality where you need to find people who are passionate, want to do the right thing and change culture. Then, they become your facilitator driving it, so they feel they own the topic and want to make a change.

Amanda Raad: You clearly have a mature BCA network now, but what do you do with that in place? What are some of the steps that you take to grow and nourish it? And what are some of the changes that you’re making over time?

Alexandra Belmonte: A recent change we had done last year was to change the perception that they should be our ears and eyes on the ground to become the voice. That was also based on feedback from the BCAs that, “We want to do more than we’re doing now. We want to be more active.” We take feedback from them on a yearly basis, and then, adapt that into the program. Then, of course, we look at the company itself—how it’s growing, where the risks are changing—and then, we change the BCA program in that respect as well. As I mentioned, they started as an anti-corruption, negating risk factor, but they are actually supporters on all the compliance topics. We’re also bringing in a fraud element, which is managed by a different team. We are looking at growing the BCA network. We started with just entities, and now, we have expanded to also include functions that handle critical risks. It would be wonderful if we could have a BCA in each and every entity—slowly we’re getting there.

[22:50] Concluding Discussion and Key Takeaways

Amanda Raad: Amazing progress, Alexandra. To have a network of business compliance ambassadors, you’ve given us so many great tips. But I’m going to ask Richard first: What’s your key takeaway?

Richard Bistrong: I think the building blocks. Start small. Find your rising stars. Find your influencers. Start smart. Look at what your risk areas are. Make sure that you have management buy-in. And also, the appreciation that this is to drive culture. Alexandra, thank you for really taking what a lot of compliance leaders might think of as something that’s too daunting and realizing you don’t have to start big—you can start one step at a time.

Amanda Raad: I’m going to go back to where we started, with you leaning into the challenging, because you had courage. Get up each day and face it with a bit of courage. I think bringing that to the work that we do, including with compliance ambassadors, is so important—I love that. I think bringing that to all that we do is refreshing, and you gave us so many great tips. But what about you, Alexandra? Is there anything that you would want to add, one thing that you think that maybe we haven’t touched on or that you just think people should be thinking about when we’re thinking about the global world that we all operate in, in culture, in risk, and all the topics that we all love? Any departing thoughts?

Alexandra Belmonte: I think stay positive and see the good in people. So, think the best of people, because that brings you a long way. When you start the day and you’re met with a smile, it makes a world of difference instead of facing a grumpy face. And then, ask the questions, because you don’t know if you’re going to get the “Yes” or “No” until you ask the questions. I think a lot of opportunity is gone because people simply don’t dare to ask.

Amanda Raad: I love it. Alexandra, thank you so much for a stimulating discussion—it was really wonderful. Where can listeners find out more about you and the work that you do?

Alexandra Belmonte: They can visit maersk.com, where we have a fantastic sustainability report—they can read about more than compliance, but they will see how it all fits together. Then, we have MACN’s website, where you can read about industry initiatives and get lots of inspiration. And then, of course, you have LinkedIn, where Maersk has its account, and people from the compliance team are posting things.

Amanda Raad: Thank you all for tuning in to the latest episode in our Culture & Compliance Chronicles series. For more information about our series and any of the ideas discussed, take a look at the links in our show notes. You can also subscribe to the series wherever you regularly listen to podcasts, including on Apple and Spotify. We’ll be back very soon for our next chapter. If you have topics that you would like us to cover or novel perspectives you want everyone else to hear about, please get in touch. Thanks again for listening. Have a wonderful day, and stay curious.

Show Notes:

• A.P. Moller - Maersk: maersk.com
• A.P. Moller - Maersk LinkedIn: https://www.linkedin.com/company/maersk-group/
• Maritime Anti-Corruption Network (MACN): https://macn.dk/