Leveraging Policies and Culture: A Recipe for Success

When establishing and running their compliance programs, fund managers confront the tension between focusing on fostering a strong culture of compliance on one hand and guiding employee behavior by enacting and enforcing rules on the other. In a guest article, Anna Romberg, executive vice president of legal, compliance and governance at Getinge, a Swedish life sciences company, and Ann Sultan, a member at Miller & Chevalier, explore the differences between rules- and culture-based approaches toward ethics and compliance, drawing on their experiences working with U.S. and European companies. They also note differences in the application of ethics and compliance programs depending on geographical orientation. For more on fostering a culture of compliance, see “How CCOs Can Avoid Personal Liability for Organizations’ Compliance Failures” (Mar. 11, 2021); and “CFTC Enforcement Division Aims to Foster ‘True Culture of Compliance,’ According to Report” (Jan. 16, 2020).

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