Integrity and Ethics: A competitive advantage in business

Interview with AT&T Chief Compliance Officer, David Huntley


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Recently, AT&T announced its $80bn acquisition of Time Warner. Days prior to the announcement of the deal, New Europe’s Editor, Alexandros Koronakis, sat down with the telecom giant’s Senior Executive Vice President and Chief Compliance Officer, David Huntley, to talk about what it takes to operate on a global landscape.

Huntley has been in this role at AT&T since December 2014, following a number of key senior leadership roles, including assistant general counsel, general counsel and secretary for all legal functions of Advertising Solutions and Interactive operations, and Senior Vice President of Mobility Customer Service Centres.

As the interview commenced, the gravitas of Huntley’s role, and his vast work experience started to radiate in the room. But it only took a few moments to realise that there was much more to the man. The Fitbit on his hand caught my attention. Huntley, 58, later told me that he was running three miles every morning.

The first thing that I wanted to know, is ‘What does a Chief Compliance Officer do?’

“I’m responsible for verifying our company’s compliance with all rules, regulations, and laws, wherever we do business, and also safeguarding our customer and employee information,” Huntley explained. “But it’s much more than just internal policies and controls. It’s also about promoting a culture of ethics, integrity and trust. When you build on a foundation of personal responsibility and integrity, compliance follows. We believe that is a strategic advantage for us.”

The company already has a strong presence in the European capital of Brussels, so what was Huntley doing visiting the EU capital?

“We’ve grown globally, especially with our expansion into Mexico and the acquisition of DirecTV. We have a strong customer base and presence in Europe, and so it was natural for me to visit our employees in Brussels, as well as meet with officials and regulators in the EU.”

In retrospect, we will never know if any of Huntley’s meetings had something with the Time Warner acquisition, but it would not be surprising if that was the case considering that the European Commission’s competition authorities will be called upon to sign off on the deal.

The job description of a Corporate Compliance Officer (CCO) sounded not just daunting, but impossible.  In some countries in which AT&T operates, the legal and regulatory frameworks can change very quickly. I asked Huntley about how easy it is to stay ahead of such developments.

““Having the right talent and technology is vital for staying ahead of the changing landscape. You have to have technology that helps you, and you have to know what laws and regulations are coming down. We have a great relationship with our external affairs organisation whose primary responsibility is to be on the lookout for legislation. I had that responsibility at one point in time so I have an appreciation for people who watch the legislative process and have their fingers on the pulse of that process. More importantly, people who also understand the entire business, the initiatives and objectives of the company, who have an appreciation and sensitivity for those areas, are essential. It’s much more sophisticated today than it was 10-15 years ago. “

The big question all the countries would like to know, particularly in Europe, is what they can do to attract big investment from companies as large as AT&T. I asked Huntley how the legal and regulatory environments factor in when it comes to AT&T to investing in a country or region.

“It’s pretty simple. We want to be treated fairly. Whenever we seek to do business in a jurisdiction, we look for a level playing field, we look for consistency across the board when it comes to the application of the rules and regulations. We believe in market forces coupled with light-touch regulatory practices.”

EU countries certainly have some of these qualities. “Should we expect some AT&T projects in Europe in the near future? If not, what would help, through the perspective of your role, to make that happen?” I asked Huntley.

“AT&T is always looking to make investments where we think we can have a return – we are always looking for opportunities, and instances where this can happen.”

Looking down at Huntley’s rubber bracelet that read ‘world peace’ I wondered about how difficult it must be to spread the culture of compliance, and the deeper notion of ethics in an organization as large as AT&T.

“It begins and ends with ethical culture. The foundation of our culture centres on integrity and trust – Operating with integrity and trust is one of AT&T’s four values. One of the things that I did when I took this role was to start a campaign around the notion of ‘just do the right thing’. The notion is that you know what the right thing is.”

Huntley explained that the word ‘just’ is critical, as it implies that the individuals involved already know what the right thing is, and all that is left is for them to apply it. Where as saying ‘do the right thing’ would be dictating instructions.

“This was about [our employees] empowerment. It was about them taking the personal responsibility for this [and] how that represented who we are and how we do business.”

Was it successful? At the end of the year, 94% of employees of AT&T were familiar with the central tenants of the campaign.

“From there it was about making sure we put tools and training in the hands of employees who have to do that.”

The results of course, have to be monitored. “We have to inspect what we expect,” Huntley remarked, continuing to explain the reminders people get and the specifics of the tools at their disposal to check at any moment via their smart phone whether what they are doing is in line with company policy. “If they are still not sure, they have a number they can call and ask,” he said.

Continuing the interview, I moved to the difficulties of the global economy. In the face of globalization, and particularly when it comes to countries which are very difficult to navigate, with protectionist attitudes and corrupt governance, I asked Huntley why it is important to see his position – that of a Chief Compliance Officer an asset rather than a liability that can hinder growth.

“We don’t see it that way,” Huntley retorted, “Companies, and there are statistics that prove this, that focus on ethics and integrity experience 16% higher returns than those who don’t.” But the buck doesn’t stop there; these companies have a greater commitment from their employees as well as greater productivity.  I can tell you that people prefer to buy their services from companies that focus on integrity.”

Huntley’s passion for the topic was apparent as he pushed on to emphasize his point about the viral power of integrity:

“I think just the opposite. Focusing on being compliant, and focus on integrity can be a competitive advantage. It’s why people trust you, it’s why shareholders invest in you, it’s why customers buy your products and services, it’s why people come to work for you.”

We continued the discussion on the realities of doing business:

“Corruption can sometimes be perceived as a high price for doing business in a particular jurisdiction or location. When you take that out of the equation and establish that it won’t be tolerated, it’s good for everybody. It’s good for the people in that country and it’s good for the transparency of regulators,” Huntley explained.

He went on to recount an issue where an employee had been offered a bribe, in a new market the company was entering. The employee had reported the attempt, and felt proud in doing so.  But what struck Huntley most, was the response of the other AT&T employees in his team when they had found out what happened.

“We openly talked about the situation and recognised his actions in front of his peers, and I will never forget how people jumped to their feet to applaud.”

The spontaneous applause turned into long, victorious standing ovation. Finishing this story, Huntley had an expression on his face of pride and satisfaction.

Huntley’s demeanour was stiff but in command sitting down for the interview. He looked and acted like someone being vetted to be a presidential nominee. However, his humanity took centre stage once he began talking about his father, who worked as a chauffeur. “My personal fabric comes from my father … a man of integrity and high-moral fibre. He wasn’t wealthy but he was moral. I saw how people reacted to him, and I wanted people to react in the same way [to me]”

I had asked Huntley if he carries a strong code of ethics in his personal life, but I already knew the answer before he began to respond.

“This isn’t about checking a box. It’s about doing the right thing, even when people aren’t watching.” Huntley conceded that integrity is something you have to work at. “The Little test”, as he referred to it, was whether you cross an empty street when there is a red pedestrian light.

How can he know employees will live by the code?

“At the end of the day”, Huntley concluded, “you only ever know when someone is put to the test”.

To end on a high note, I asked about the US elections, which have been taking a toll on the everyday citizen and polarising society.

“Do you think both sides of the presidential campaign need a Chief Compliance Officer?” I asked.

Huntley just smiled.

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