Transcript: Running a Global Compliance Program from Shanghai

· Transcripts - CBLP

Shirley: So one of my key takeaway and I seen that it's a takeaway applicable to a lot of senior managers is after COVID we're facing a new normal. So how we balance our work and life is called work-life integration. Ease that off work-life balance as a professional in this industry for around 20 years, I think we all have a commitment to the society debt.

How would we value things, as young people, as a young community, and broaden their horizon and also how we can help them. I think that's one of my goals.

Kim: Welcome to the China business law podcast. I'm your guest host today. My name is Boon Kim Fam and I go by Kim. We are very honored today to welcome Ms. Shirley Zhang, the Global Compliance Director for Dover Fueling Solutions, a company that has a combined heritage of 450 years. They have over 2,800 employees globally with products sold in 150 countries.

So Shirley has more than 18 years of compliance related experience on due diligence sanctions and export controls anti-corruption and risk assessment in different regions. She has also practiced in different industries, including, but not limited to FMCG pharmaceuticals, special chemicals.

And of course, we welcome Shirley to the China Business Law Podcast today.

Shirley: Thanks Kim. And hello everyone. This is shortly. It's a privilege for me to join the session and I'm really looking forward to our interview today. 

Kim: Thank you, Shirley. It's such a pleasure to have you here. So Shirley you're responsible for your company's compliance program globally, and you are here based in Shanghai.

So help me understand how big is your team globally and where are they based? 

Shirley: Thanks, Kim. We have a very lean team globally, so I based, I currently based in Shanghai, China, and we have different team members who based in Austin, which is US, Texas, Dundee in UK. And Rio in Brazil, India and also another lady who based in or China.

So that's my team globally. Okay. 

Kim: Well, so basically, how do you manage in terms of the challenge? Or advantages that you can see running a compliance program globally with people all over the globe and you actually based in Shanghai are all, those would be very interested and curious to find out how does this work?

Shirley: Yeah, it came. That's a very good question. Actually, I've been asked this question multiple times in my past 18 months because it being very transparent and honest here it is. Regardless it's live challenge or, or know a challenge from different time zones, from a working experience, and also how you meet people connected with your key stakeholders.

So one of my key take away, and I think it's a takeaway applicable to a lot of senior managers around the globe is after. Well, during the COVID that we are a new norm, we're facing a new norm episode. So how we balance our work and life, I use a new word, which I created, or maybe I don't know, from some other newspapers is called work-life integration.

Instead of work-life balance, it is very important that we need to leverage the time. And also the efforts that we have. I wake up like 6:00 AM, because anyway, I need to prepare the kids for school, but starting from 60 6:00 AM six 30, like my attempt to you and my us team, which is 7:30 PM or 6:30 PM.

Then I still can get some connection with them or definitely they need to balance their time with me as well. Keep working on that. I'll be honest here. I do take a cat to nap during my daytime because 15 hours per day, it's a, it's a really challenge for everyone. After that I think do some personal events.

And though, of course you're having some exercise, like work culture, like Kim do every day, try to touch you have a strong board and a strong mindset on dads, but definitely starting from nighttime to 7:00 PM my Europe time. And also. North American, not 10, 10 time. It came up again. I don't know if I answered a question in a well manner or not, but that's how I balance my, 

Kim: I think you've actually laid it out beautifully.

There's time for your children. There's time for the Latin American team. There's time for the us team. The time for the Asia team, you are spread pretty thinly, but I'm really pleased that you will still have time to actually maintain as you put it beautifully. Work life integration, which is something that even including people like myself, we have to consistently balance this challenge.

But I think if we don't take care of ourselves first, how are we going to be able to, to exercise our roles effectively and efficiently? Yeah. That's a very good point. So thank you for sharing that with us. Sure. Appreciate it. Because you mentioned COVID 19 and I'm pretty sure like many other companies and none of us are immune to this.

International travel has been difficult. If not impossible at times. So just curious to know, and I think our listeners, our audience would also be curious to know as well, has this in any way changed the way that the compliance program has been run at your company? 

Shirley: Yeah, I'll say the compliance program. It definitely has been heavily impacted globally, regardless which industry. Because we are facing the challenge of that less and less face to face meeting will be held. So I think every company, every industry will move from online to virtual meetings like teams, Yammer post, what else? There's a very new norm.

I don't know. I forgot the name, but they have zoom. Yeah. Yeah. WebEx. So all these meetings right. Will definitely help, but. I think the most impact that we have, or my view from a global compliance officer is how we make it relevant to our industry. Number one, and number two is people have the psychological safety to embrace dose compress for women.

They are willing to speak up. I think these are the two elements that I would like. Put on the table and let all the audience to think about it. Because during the COVID we are all working from home or remotely. We cannot talk to people how our employee, how our key stakeholders have the trust and also psychological safety to convey your thoughts to us.

We talk in a trusty way because pre previously we can have face-to-face meetings, right? We conduct a lot of training, not only training risk assessment, which is required from a DOD perspective, which is required from a FCPA perspective and also a lot of due diligence by doing onsite review. But now we're doing it virtually by leveraging different website or some local partners who will support us, but what's our comfort.

So these are the challenges in my view that I see it will call me. And I don't think it will be how to say that word. It will go away in a short period of time. 

Kim: Exactly. I think I feel the same way as well. In speaking with other peers, some have told me that, in fact, because of the lack of face. And then we've had to communicate a lot of matters virtually to internet meetings.

Some people have actually become more comfortable speaking, speaking up. So that's a trend, which I think a lot of us have not actually anticipate. That would be the case. So it really is a different world out there right now, I think. 

Shirley: Exactly. 

Kim: Okay. So moving on to the next question for you surely. With the increase with the increasing regulatory activity on export controls and also the introduction of new laws in China, specifically the China and high sanctions law, and also the digital security law.

What global compliance trends do you see impacting your industry? 

Shirley: Generally? Yeah, that's a very good question. And I think all audience, regardless of their industry are facing here and there, these kinds of trade compliance challenges, or maybe some uncertainty or ambiguity there, I'll use the word. If it's allowed.

The reason why is we see different to government issuing different regulations or sanctions against certain list of. Or entities and with them or new requirements, actually, when that, why can give, we all know that sanctions real one impact a lot for China and the U S entities and additional tariffs burden will be bared.

And also another example I can give is we're know that a lot of new regulations are required in Europe. For example, for hazardous elements and California privilege CRO 65, which is a new requirements as well from a really hot topic from a yesterday perspective. So these are the trends that I see.

And also another good example I can give is with the new updates from different governments to put compliance and due diligence concerned, parties or entities is arising. I'll use that word. And that's something that alert all the compliance officers, how we do our. How we properly design our due diligence program and how we communicate to our key stakeholders, like our sales marketing team, also our finance team in a due diligence.

Wait, I think these are the key factors for us to consideration. Let me give one example and we all know that we have some potential sanction parties regarding. In certain countries, for example, like Myanmar or the concern that recently we had, we saw that on the newspaper and what's the impact for us.

We are okay to do business with that. But one more step for us to think about that is what's our due diligence process to give us a comfort level. Do we screen those person to make sure that they are not in the block the best, especially like a us or your company to comply with your government requires.

And also another example is what's out from a financial impact perspective. What's our commercial term, especially from a collection of payment term perspective, there is definitely, you know, because different party berries, right? Maybe you cannot exceed a 60 days or you can not exceed a night days, how we properly make sure that we, number one, if we know that what's requirement is that was based our due diligence process.

And number two is how we properly communicate to our key stakeholders. Our sales function, our marketing function and our finance team in a proper manner, in a proactive. So these are the areas that I see the trend. And also this is a new requirement for us as a compliance officer that we need to prepare our team as a business.

Kim: That all makes a lot of sense. And what I'm hearing from you is that really understanding who we're working with having a robust third party due diligence program in place is always going to be key. Right?

Shirley: Exactly. Backing process definitely is a moment. From a due diligence perspective and veting process, like we all know that, know your customer.

It's another process we talk to a lot, and this is not only for fuel from a trade compliance perspective, but also from an antique crusher perspective, because we all know that know your customer is a part of the anti-money laundry right procedure. But of course vetting your understanding who your customer, who you are dealing with is also a key elements from a compliance or anti crushing perspective.

Kim: Couldn't agree more. Thank you for that. We're going to take a back step a little bit, and I just wanted to get your thoughts in terms of, you know, like yourself. I also run a regional compliance program at Mott, quite global. We're getting there. So one of the metals that we continue to champion, of course, in the compliance space is the need to have a safe.

In order to speak up and raise issues within the company. So again, at the risk of COVID fatigue, I still have to ask this question with COVID 19 or the past year, and now either with resurgence in cases over the past year, do you think that generally speaking up has, and in challenges and also if yes, what do you think we can do in order to overcome such challenges?

Shirley: Yeah. That's a very good question. And I think these are the challenges that we be facing everyday. And how we, I guess I said it back to my point or in the early, during the interview, that how we make sure we gave a psychological safety moment to the team and they trust us and they're willing to speak up.

Right? These are all the challenges that compliance officers had been facing during the COVID and potential after the Corbett pending. I'm a strong believer that openness trust and transparency are the three pillar pillars that will allow us to maintain that momentum. Number one. And number two is you think, utilize us as a role model and also share with the management team what's the lesson learned and what we can support from a business partner perspective, definitely help improve that a lot and ultimately helped organization and help us as.

To winning the trust from our employees. 

Kim: Okay. And I really like what you mentioned about us setting the example as a role model, because the next question that I have is directly related to this. So coming back to that, setting ourselves up as role models of the company, how do you think that the role of the compliance leader has evolved, especially within senior leader?

Like in your opinion, what do you see are the hallmarks of truly gaining a meaningful seat at the leadership table? 

Shirley: That's another brilliant question. I think that's a tough question. I'll also say that how to gain a real seat. We will talk that a lot. I think you do in our previous conversation, formal or informal conversation.

I think one thing I can see is how we view. We view ourselves as a true business partner because business partner are in different areas. We promote a business or we protected a company in that ethical promotion of ethical manner. So I think what's the contribution to the company from a business world.

And from a culture perspective, I think that will help us to win a real seat. And also to echo what I just mentioned it what's the lesson learned and also what's the, what's the, uh, follow up mitigate. Action plan will help the company navigate away from those risky area will earn us a real seat in the management team.

So I keep saying, and allow me to code my favorite word is we always ask questions. We always, we have a product, right? We ask questions, but please do remember that as a compliance officer, we not only ask questions, but we provide a solution as well. 

Kim: Absolutely. Yes, with all of that and such impressive answers, as well as your insight globally, which is a very rare role.

I would like to emphasize to our audience. It's certainly for me, it's not everyday that I get to speak to somebody who has a global portfolio, and it's actually based on the Eastern side of the world or Eastern part of the world, so to speak. So you mentioned earlier about workloads. Uh, integration, work, life integrity and mop.

Just balance. I think what I'd like to give the audience and opportunities as well is to, no, no, you not just in your professional capacity, but also like from a life perspective and what plans you may have on a going forward basis. Because I think sometimes people tend to forget that as compliance officers, we are also doctors.

Mother's friends and all of it. So the personal touch, I think that's really add a fair bit of value, not just at the senior leadership level, I think throughout all layers of the organization. So of course, to the extent that you are comfortable sharing with us, if someone were to know you today for the first time, If you had to give an elevator speech, what would you like people to remember you for you think.

Shirley: wow, that's, that's hard. That's not prepared?

Kim: not prepared. I am going to actually decide if she would like to actually, I will let her determine how she would like to answer these questions, but she is a really person. And I genuinely believe we should use this platform to try and let the audience understand who is she. 

Shirley: She really is.

That's something I'm not really prepared. And I think I'm a working mom with two kids. I try my best to balance my work and life. But ultimately, as I said, I find, and I can't, but what I can do is my work-life integration that early wake up doing. My job and spend time with girls and also have my personal phone at the time.

So that's how I do that. And from a people perspective or from my personal hobby perspective, I like to read, I read a lot and Kim and I touch a lot to how we make impact and return to the society. I seen the death, something that I really want to people know from us. I encourage everyone to join us as a compliance officer, we have a commit commitment to, to the social society.

And also that's something that we can see our value, especially at my age. I do. I'm not that old, but still as that word as a professional in this industry for around 20 years, I think we all have a commitment to the society that how we bring values to the young people, young community and give them some.

And broaden their horizon and also how we can help them, help us, help the society to be a better us. I think that's one of my goal and the coach from Michelle Obama's book Becoming is when people go low, we go high. 

Kim: Wonderful. Absolutely love it. And I will also share what my late grandfather told me when he was still alive.

If you forget that the society will also forget you. So he put it very simply, but I think the meaning, ultimately our goal are very much pretty, pretty aligned. So thank you for that. And with that, we have come to the end of our episode today. I enjoyed very much recording this session with Shirley. I hope that you have also enjoyed listening to this episode as much as both Jody and I have enjoyed each other's company producing this and until the next episode, Please continue to stay safe.

And Shirley, thank you so much for your time today. Much appreciate that. And I wish you all the best, appreciate that.

Shirley: And everyone stay safe and really looking forward to this journey with. 

Kim: Wonderful. Thank you very much. Bye. For now.

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