Getting Foreign Personnel to Comply, While Respecting Cultural Differences and Allowing Some Level of Operational Independence

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Getting Foreign Personnel to Comply, While Respecting Cultural Differences and Allowing Some Level of Operational Independence

Sarah Peter, Senior Corporate Director Ethics and Anti-Corruption and Corporate Compliance Attorney, Teledyne Technologies Incorporated, USA

Multinational companies often struggle with what is the appropriate level of diligence and oversight to apply to their foreign subsidiaries, particularly those foreign subsidiaries in underdeveloped nations, or in regions with widespread corruption. It is almost an art to strike the perfect balance. On the one hand, you want to respect the fact the foreign subsidiaries have developed a routine that works, and thus would not benefit from a mandate to revamp their entire practice. On the other hand, you want the foreign subsidiary to recognize that the parent company is the final decision maker, and for the foreign subsidiary to take pride in being part of the larger team. There are stark cultural differences from one country to the next, and you risk losing credibility if you do not familiarize yourself with those differences and take them into account when establishing expectations for your foreign subsidiaries. Key elements to successfully striking the delicate balance include: (i) learning to collaborate with the foreign subsidiary, so knowledge and ideas flow both ways and are not just pushed down; (ii) demonstrating awareness and sensitivity for cultural norms; (iii) learning to trust in and have faith in your foreign operations, but nevertheless behind the scenes taking the time to verify the facts; (iv) enlisting and empowering boots on the ground at the foreign subsidiary; (v) learning to say no when it is necessary; and, (vi) conducting compliance visits and sending out compliance-related communications without overdoing it and risking dilution of the message.

Sarah Peter is the Senior Director of Ethics and Anti-Corruption and the Corporate Compliance Attorney, at Teledyne Technologies Incorporated. She is responsible for the Company’s ethics and anti-corruption programs, and also works regularly on government contracts, human trafficking, contracts and trade compliance. Ms. Peter joined the company in September of 2012. In her role she regularly visits Teledyne’s domestic and foreign offices for compliance related visits and internal investigations. Ms. Peter has also worked as an associate for a personal injury firm and a research assistant for a legal professor, and has interned with the Ventura County Public Defender’s Office and the California Innocence Project. Ms. Peter attended Pepperdine University School of Law where she graduated Order of the Coif and in the top 8% of her class. At Pepperdine, Ms. Peter was a member of the Pepperdine Law Review. She also received a certificate from the Geoffrey H. Palmer Center for Business, Entrepreneurship and the Law, a business law certificate. Ms. Peter also served as a member of the Mentor Program, and a member of the Labor and Employment Law Club. In law school, Ms. Peter was the recipient of the CALI Excellence for the Future Awards, i.e. best in class, for the following subjects: Contracts; Corporations; Antitrust; Employment Law; and, Intellectual Property. Ms. Peter received her undergraduate degree from the University of California, Los Angeles (UCLA) with a Bachelor’s of Art in Psychology and a Minor in Public Policy. Ms. Peter graduated Magna Cum Laude with a 3.8 GPA.

Teledyne Technologies Incorporated is a high-technology multi-national publically traded manufacturing company with approximately $2.3B in annual revenue and 9,000 employees worldwide that provides enabling technologies for industrial growth markets. It has evolved from a company that was primarily focused on aerospace and defense to one that serves multiple markets that require advanced technology and high reliability. These markets include deepwater oil and gas exploration and production, oceanographic research, air and water quality environmental monitoring, factory automation and medical imaging. Its products include monitoring instrumentation for marine and environmental applications, harsh environment interconnects, electronic test and measurement equipment, digital imaging sensors and cameras, aircraft information management systems, and defense electronics and satellite communication subsystems. It also supplies engineered systems for defense, space, environmental and energy applications.

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