E&C Pulse - January 22, 2019

January 22, 2019 Ben DiPietro

Going Inside the Mind of a Chief Compliance Officerprofile_pics_5

Ellen Hunt is the senior vice president and audit, ethics and compliance officer at AARP, which used to be known as the American Association of Retired Persons until a rebranding five years ago changed it to the American Association of Real Possibilities.

Hunt, who since 2011 has been with the organization devoted to enhancing the lives of people aged 50 and older in various compliance leadership positions, spoke to the LRN team last week about her job.

She described what she’s trying to achieve, how she sets her budget, and what she looks for when evaluating vendors offering products and services to the organization with around 38 million members. Here is part one of my Q&A with her.

What are AARP’s E&C objectives for 2019?

Hunt: One of the things everybody struggles with is how do you get the message across in a new and a fresh way. I’m very interested in thinking about new ways that I can get messages across in very short spurts. I don’t want to be in front of people necessarily, lecturing them…[but] you’re never going to be a successful employee here if you do not adhere to our ethical expectations. I really want to focus on them as an individual and how they behave.

I’m looking at things like, how do I get a one-day message when they turn on their computer? How do I get a message throughout the building on the TV monitors? How much do I message outside the normal communication avenues? How do I give them short little tests to just test them about what they know in a way that doesn’t embarrass them or otherwise put them on the spot? How do I deliver training that actually sticks. 

The other thing I am very interested and focused on is data analytics. I’m very focused on forging an even-closer partnership with human resources, it’s got a lot of that data. And really putting ethics and compliance out there--not as a one-off thing where we have to go into a room and spend time on--but as something we do each and every day.  

How is your budget figured? What does the budget cover? Is there money for E&C in other department budgets?

Hunt: My situation might be little more unique. My budget has stayed the same in all the years I’ve been there (2011). My challenge is I have to keep delivering the same plus more with the same amount of money. Most of my budget goes to my personnel.

People as part of their performance review, they’re graded on their efficiency. We sit down as a department and say, ‘What can we stop? Where are we spending money and doing things that don’t add any value?’ It’s easy to keep on the treadmill, doing the same old things, but if you are producing reports or information and taking time on things that don’t matter to your constituents, why are you doing this?

Where we really spend our money is for our case management system, that’s really our largest vendor. Training has transferred to HR, which is good and bad. On the one hand, I have their help and support; on the other hand, I have to negotiate with them about my training and my courses.

What say does the board have in setting E&C goals, budget?

Hunt: I report to audit committee, and within our organization three audit chairs: one for the association, one for the foundation, and one for the for-profit arm. All three of those individuals have input and influence over my performance review, as well, and we have a planning session about what we’re going to do in the future. I have never had them say you must do this, but I want to gather their input and their thoughts about what they think is important.

How do you buy services and products? What services and products do you buy?

Hunt: IT runs probably pretty much every organization. I don’t think I would be unique in that I had an app or a chatbox, or some other type of communication vehicle, I’ve gone off and done an RFP, I’ve got a couple of vendors I am interested in and then IT gets involved and sometimes the deal just dies. Because--and rightly so-they’re looking at what goes across the enterprise, what fits in with our architecture, and frankly they speak a different language than I do...so I go into some of these meetings and they are talking about stuff I don’t understand.

I just want stuff to work, I don’t want to waste money, and so if there’s something else in the organization that fits my needs, that’s fine. But I think it’s terribly important...to get other stakeholders involved. IT can kill the deal if they don’t like the products, or the platform or architecture, you might not be able to get very far. It’s important to get IT in early.

The other stakeholder I would think is very important is HR. Sometimes they get very territorial and very protective about something that touches every single employee, so get stakeholders in early, include them, get them in there often. Because you may think you have a deal, and then you don’t.

How do you decide who to work with? How important is the personal relationship with the sales person?

Hunt: One of the things that concerns me about some of these relationships is I’m putting my ability to deliver in [their] hands. If that means I can’t get a report when I need it to report to my audit committee, that’s a problem. I can’t really be so dependent on my vendor that I can’t do my job. That’s where the relationship can be a really key factor to me. I need to be able to get the training I need to use the product, I need to get the customer support I need, I need the customization.

In some instances, the E&C person is the easiest one to sell. How can sales people work with E&C to get support and backing throughout the rest of the company?

Hunt: One of the things I have found to be most effective with my IT team is...I say to them, ‘You know, Google does it, Amazon does it, blah blah does it.’ What I am appealing to is, we love to be in the herd with everyone, and the challenge is if they can do it, how come we can’t? So what I think is really important is providing me with that information about who are your other clients that are using it, and what are their success stories? And I want to get on the phone with the IT person to your client referral. That speaks volumes. Somebody else who’s been through the process and it’s been a success.

But we often do it way at the end instead of in the beginning. I’ve been trying to work with my IT folks saying, ‘Look, they’ve got three folks we can call, let’s do a little due diligence ourselves,’ and we do. One of the questions we ask is what do you wish you knew that you know now? What was the hiccup, the hurdle, the one problem you may be encountered? When I’ve got someone at another company, when they say, ‘I’ve done this and this is the benefit, it was great, customer service is wonderful,’ I’m ready to sign.

How should sales approach IT?

Hunt: What happens to IT is they get caught by surprise, you’re halfway down the RFP process or whatever and they’re going like, ‘Oh, great, another one I have to deal with.’ They have their own priorities and guess what, E&C is never going to be one of those.

So really suggesting that stakeholder buy-in sooner, earlier, but also have your tech people on the phone so they can have that conversation in their own special language sooner, that can go a really long way. My experience has been some of that stuff is not that unique, they just don’t know what you guys have, you’ve got to have that meet-and-greet conversation, and the sooner you have it the better. They just have to get comfortable with you. 


Ben DiPietro



A report last year from LRN on how to operationalize an ethics and compliance program found 39% of respondents said their training programs aren't accessible on mobile devices.



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In his annual letter to chief executives, BlackRock's Larry Fink says CEOs need to take stronger leadership positions in the world, as corporate participation is vital to solving many of the world's biggest problems. Boards need to listen to what Fink is saying, attorney Michael Peregrine writes in Forbes.

A Bloomberg analysis of 12 billionaires attending Davos found their combined wealth grew by $175 billion since the worldwide recession in 2009. Meanwhile, AP reports anti-poverty organization Oxfam reports income inequality worldwide is "out of control."

Thirteen women who sit on some California's largest public pension fund boards want companies to provide more information on their costs associated with sexual harassment, and to map out a plan for dealing with the problem, Bloomberg reports. 

The need to deliver on corporate brand purpose is the top micro-trend for 2019, Reputation Institute writes. But brand purpose doesn't work when it's more about marketing and less about values and behavior, and the phrase may be losing all meaning, consultant Brian Millar writes in Fast Company.

The FCPA Blog looks at how companies can nudge their employees to behave better through the use of behavioral economics.

Is corporate activism leaving the healthcare industry behind? Dana Davis asks the question in PM360.  



Increase employee engagement with LRN's new platform tool that allows compliance and communication teams to deliver targeted, high-quality messaging to their diverse global businesses on key ethics and compliance topics and risk areas.



Join LRN CEO Dov Seidman and Zainab Salbi, humanitarian, media host, author, and founder and former CEO of Washington-based Women for Women International as they discuss Zainab's highly personal new book, Freedom is an Inside Job, and the impact of freedom on the way we lead in a more conflicted world.


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