LRN Perspectives

Global Ethics and Compliance With a Local Flavor: Jonathan Drimmer on Tailoring Values-Based Programs for Multinationals

November 12, 2019 LRN Corporation

“Training moved away from a focus on rules and towards approaches that looked to connect personal values to company values to community values.”

 – Jonathan Drimmer

On this episode of the Principled podcast, host Ben DiPietro, editor of LRN’s ENC Newsletter, interviews Jonathan Drimmer, a Partner of the law firm, Paul Hastings, LLP. Prior to his current role, Jonathan was the Chief Compliance Officer at Barrack Gold, a large mining company, where he worked to improve the programs across five continents, including workforce engagement, training, monitoring through metrics, driving company culture through behavioral modelling, and using values to positively identify third parties to work with. Jonathan explains how a one-size-fits-all Compliance program doesn’t work for a multinational company, and how programs, training and engagement can all be improved by taking a hyper-local approach to each locale.


  • [0:58] Tell us about the journey from being a lawyer to getting into Ethics and Compliance.
  • [1:06] After clerking, Jonathan had a one-year internship in the Solicitor General’s Office, which brought him to Washington and gave him a bird’s eye view of the Department of Justice, where he then worked for seven years as a Deputy Director in a criminal division. After that, Jonathan joined a law firm and worked in anti-corruption and business and human rights issues, where his work in Ethics and Compliance began. He was also the Chief Compliance Officer of Barrick Gold from 2011 to 2018.
  • [2:32] What are you doing now in your new role at Paul Hastings?
  • [2:34] Jonathan’s focus at Paul Hastings is on cross-border compliance, enforcement and disputes with an emphasis on the natural resources sector.
  • [3:25] During your time at Barrack, what were the main Ethics and Compliance challenges you faced and how did you handle those? How did the program change or improve during your tenue there?
  • [3:36] Barrack operated on five continents, and mines operate like small cities themselves in remote locations in developing countries. Permits and licenses are required on just about everything, in addition to Visas and work permits required for ex-pats, as well as adjusting to local taxes and public security. Key improvements made were workforce engagement, identifying effective metrics and KPIs to measure performance, positive culture shifts, and the modelling of behaviors by management.
  • [6:29] How did you deal with the issues of far flung jurisdictions when integrating the Ethics and Compliance program with the Human Rights program.
  • [6:43] Diversity of jurisdictions was a challenge, and the risks you face in one location are different than those you face in another, often within a single country; the risks are hyper-local. The global Compliance program was an umbrella to encompass separate, tailored local Compliance programs for each individual site or mine, which addressed local fraud schemes, human rights risks and challenging government officials.
  • [8:49] What are some tips you can share to ensure program consistency and yet still be specific to each locale that you are doing business in?
  • [8:57] One-size-fits-all approaches just don’t work. The best solution is a series of individualized programs for each location. The consistency surrounds the infrastructure, the rigor, and the continued message about the importance of Ethics and Compliance.
  • [10:04] How can training better engage stakeholders in the company’s Ethics and Compliance program?
  • [10:15] Training and messaging is most effective when it connects to people on an individual level. Pictures that show what human right violations or corruption look like are very effective at connecting to people on an emotional level. Local experiences and stories are also powerful at explaining how the programs are improving workers’ daily lives.
  • [12:15] What are two things that companies should do, but often don’t, to better embed Ethics and Compliance in the organization?
  • [12:23] The first is program reporting on Ethics and Compliance in a way that is consistent with how other business units report, which builds trust, facilitates buy-in and improves transparency. The second is program presentation. Use short policies that are succinct and written in plain language to make it easy to comply. Use infographics or videos instead of long guidance documents, and let people take the training when it’s convenient for them, in an online format.
  • [14:10] What are some tips you can provide for Ethics and Compliance professionals to build key relationships that bolster buy-in and support in organizations?
  • [14:26] The most important thing is to understand how the business operates, and what its particular cultural nuances are on a functional unit basis. Go out in the field, see how things work, watch the business, participate and ask lots of questions. Relationships will naturally follow, as will respect for you and your advice going forward.
  • [15:32] What do you predict will be happening in Ethics and Compliance over the next 10 or 25 years?
  • [15:46] It’s going to be completely different, simply based on how substantially it’s changed over the last five years. Ethics and Compliance will include a much wider range of issues than it does now, and human rights, cyber privacy and reputation management will all be a very large part of every serious program.

    Don’t miss our next episode! Be sure to subscribe to Principled on Spotify, Apple Podcasts, Google Play or wherever you listen to podcasts.
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