Code Corner:
Compliance is Nothing to Fear
A message from Craig Johnson, chief compliance officer for ITT.
2007 is going to be a busy year for compliance and ethics at ITT.
Steve Loranger and the Executive Council have entrusted me to lead this initiative as our new chief compliance officer. In this role I will be responsible for overseeing and directing all of our domestic and international ethics and compliance efforts; meeting the government's mandates, including international compliance; and helping us ensure the ethical integrity of the corporation.
I will obviously be relying heavily upon Cornett Lewers, director of corporate compliance programs, Sue Ringler, senior counsel for international compliance, Dave Tarbell, director of international trade and compliance, and the entire compliance staff.
A comprehensive compliance and ethics program is one of the six improvement priorities for the corporation in 2007. The purpose of this improvement priority is to focus on ITT's commitment to a culture built on the highest ethical values, including honesty, trustworthiness, and integrity. The effort will center on deeds and actions, rather than simply on words. It will promote an open communications environment in which employees feel free to discuss issues and concerns with management.
While the initial activities will be aimed at those in leadership positions, the ultimate goal will be to instill in every ITT employee, all the way to the shop floor, the company’s complete commitment to conducting its activities in an ethical manner that builds trust with all constituents: employees, customers, shareholders, regulators and communities. This expectation is the key to our success in achieving this improvement priority. Each ITT employee needs to do everything we can to embed our commitment, ownership and accountability to a culture of compliance and ethics in our everyday action and responsibilities.
In the coming weeks you will be receiving more details about an assessment of the ethical culture at ITT. Soon thereafter you can expect to see senior leadership engaging you and your colleagues in ethics and compliance training. We expect to be conducting targeted training for those in what we call the high risk areas, and we will continue to train compliance experts as an additional resource for your value center.
Compliance is nothing to fear. In fact it is easy -- all you have to do is ask. If you are not sure of the answer, elevate the issue to those who know. If the answer is not clear we can figure it out. Always remember that if we conduct our regulatory activities under the bright light of day we can resolve them successfully for ITT.
Craig Johnson
Craig Johnson joined ITT in 1994, and is now serving as deputy general counsel and chief compliance officer from ITT headquarters in White Plains, New York. Prior to joining ITT, he was of counsel to the law firm of Gibbons, Del Deo, Dolan, Griffinger & Vecchione in New Jersey. He spent eight years at the United States Department of Justice in Washington D.C. where he prosecuted numerous high profile cases. Prior to joining the Department of Justice, he was an attorney at the United States Department of Energy and a law clerk for the United States District Courts. He is a graduate of Cornell University and Syracuse University Law School.
