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Fraud Leadership: The Role of Ethics, Compliance, and Culture Andy Wilson, CFE, CPP Vice President, Fraud & Compliance Sedgwick Claims Management Services, Inc.

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Page 1: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: The Role of Ethics,

Compliance, and Culture

Andy Wilson, CFE, CPP

Vice President, Fraud & Compliance

Sedgwick Claims Management Services, Inc.

Page 2: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: Ethics, Compliance & Culture

R. A. (Andy) Wilson, CFE, CSEP

Vice President

Sedgwick Claims Management Services

Page 3: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Learning Objectives

Overview of ethics, compliance & culture

How are things at your shop Tone, mood, buzz

Fraud leadership

Let’s talk ethics Ethical standards

Laws, regulations, rules ~ a world of compliance The Code

Compliance best practices

Culture ~ embrace it or change it Embrace the culture

The culture can change

Page 4: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: Ethics, Compliance & Culture

R. A. (Andy) Wilson, CFE, CSEP

Vice President

Sedgwick Claims Management Services

Overview

Page 5: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

The role of ethics ~ guiding principles

The role of compliance ~ meeting legal obligations

The rule of culture ~ how it works

Overview …

Page 6: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: Ethics, Compliance & Culture

R. A. (Andy) Wilson, CFE, CSEP

Vice President

Sedgwick Claims Management Services

How are things at your shop?

Page 7: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Tone at the top

Mood in the middle

Buzz at the bottom

Tone, mood & buzz …

Page 8: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Highly educated with advanced degrees

Well trained in positions beyond fraud

Broad organizational and industry experience

Subject matter expertise:

– Publish

– Speak

– Mentor

Fraud leadership …

Page 9: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: Ethics, Compliance & Culture

R. A. (Andy) Wilson, CFE, CSEP

Vice President

Sedgwick Claims Management Services

Let’s talk ethics

Page 10: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

To be trusted

Boy Scout

Promises made and commitments made

Trustworthiness is the key…

Page 11: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Words

Actions

Deeds

No deception

– Misrepresent: Facts

Overstating

Exaggerating

Partial truths

Honesty to a fault …

Page 12: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Personal integrity

– Customers

– Colleagues

– Supervisors

Moral courage to do the right thing

Moral code

Integrity shows great character …

Page 13: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Loyalty

– Company

– Team

– Self

Loyalty vs. independent judgment

Be loyal to self and others …

Page 14: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Active & positive leadership role

– Positive role model

Create the environment

Ethical mentality

– Lead by: Example (thought, word and deed)

Leadership is essential …

Page 15: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Personal

Business

Always pursuing excellence

Deliver excellence …

Page 16: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Treat everyone like you care and with respect

– Courteous

– Equal treatment

Fairness, tolerance and diversity

Golden Rule

Enhance morale

Respect others …

Page 17: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Be accountable to one’s self

– Acknowledge and accept personal responsibility

Obey the law

You …

Page 18: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: Ethics, Compliance & Culture

R. A. (Andy) Wilson, CFE, CSEP

Vice President

Sedgwick Claims Management Services

Laws, regulations, rules: a world of compliance

Page 19: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Cornerstone of a robust compliance program

– Standards

– Attitudes

Applies to:

– Board

– Management

– Colleagues

– Vendors

– Contractors

Code of Conduct …

Page 20: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

To deliver excellence

To operate openly and with integrity

To embrace change

To grow as individuals

To operate as one company, one team

Sedgwick’s Core Values …

Page 21: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

1

2

3

4

5

6

Others …

Page 22: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Leadership understanding

Provides support

Allows for organizational change

Communicate with the “chiefs” …

Page 23: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Work in progress

Always lean forward

Work is never done …

Page 24: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Work in progress

Always lean forward

Communication is essential …

Page 25: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Buy-in from others

Doing the right thing is the right thing to do

Lead or support

– Be a leader

– Let others be a leader and show support

Leverage the support of others …

Page 26: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Important

Takes:

– Time

– Organizational acceptance

Foster a culture of compliance …

Page 27: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: Ethics, Compliance & Culture

R. A. (Andy) Wilson, CFE, CSEP

Vice President

Sedgwick Claims Management Services

Culture: embrace it or change it

Page 28: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Buy-in from others

Doing the right thing is the right thing to do

Lead or support

– Be a leader

– Let others be a leader and show support

Embrace the culture …

Page 29: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

First day CEO/COO

Culture is complex

– Do not be detoured

– Use culture as a lever Machine vs. cogs

Dimensions:

– Symbolic reminders

– Keystone behaviors

– Mind-sets

Change the culture …

Page 30: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Deeply embedded cultures:

– Upgrades

– Overhauls

Can’t get a new one (i.e., swap a CPU)

Culture is what it is

Work within the culture:

– Components Good

Bad

– Understand it/recognize it What is preeminent and consistent

Which helps and what hinders

Work within the culture …

Page 31: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Common belief:

– Change behavior ~ heart and minds follow

– Overhauls

Culture is more about doing than saying

– Glossy brochures don’t work

People:

– Do - act their way into believing

– Don’t - thinking their way into acting

A good place to start:

– Tangible

– Actionable

– Repeatable

– Observable

– Measurable

Change behavior, mind-sets follow …

Key behaviors

Page 32: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Conventional wisdom advocates:

– Change everything that is not perfect

– Perfect to who?

Be rigorously selective on picking behaviors to focus

Consider behaviors with the greatest impact

Look to successful implementations of other programs:

– Seek guidance from those stakeholders

– Emulate if possible

Translate the critical behaviors into simple, practical steps people

can take everyday

Focus on the “critical few” …

Page 33: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Deploy authentic informal leaders

– We know that leadership is a natural attribute

– Informal leaders: In all organizations

Usually not recognized as leaders

Underused when driving culture

– Show the culture by doing it!

Don’t let formal leaders off the hook

– Don’t let colleague resources be the champion of culture

– Leaders across the organizational own it: Safeguarding and championing desired behaviors

Energizing personal feelings

Reinforcing cultural alignment

– This sends the signal and sets the tone

Leaders …

Tone at the Top

Page 34: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Notoriety - happens in quick cycles

When people hear but don’t see:

– It is bad news when hear of new and wonderful initiatives

– But do not see any activity related to it Causes people to be cynical

Use cross-organizational methods

– Portal

– Blogs, posts and tweets

– Facebook

Manage the culture over time:

– Changes over time

Demonstrate impact quickly …

By informal leaders

Page 35: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Culture is powerful:

– Challenging

– Multi-dimensional

– Difficult to deal with

Living in the culture …

Page 36: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: Ethics, Compliance & Culture

R. A. (Andy) Wilson, CFE, CSEP

Vice President

Sedgwick Claims Management Services

Questions & Answers

Page 37: Fraud Leadership: The Role of Ethics, Compliance, and Culture · Learning Objectives Overview of ethics, compliance & culture How are things at your shop Tone, mood, buzz Fraud leadership

Fraud Leadership: The Role of Ethics,

Compliance, and Culture

Andy Wilson, CFE, CPP

Vice President, Fraud & Compliance

Sedgwick Claims Management Services, Inc.