Raphael Richmond had been Ford Motor Co.’s global director of compliance for about seven months when she was invited by corporate secretary Bradley Gayton to imagine the future of compliance. It was November 2013, and she thought the company had “terrific policies” and “a great code of conduct,” she says. But she sometimes wondered what all compliance chiefs must wonder at times: “How do we know if our communications are working?”
She might have added a question that keeps compliance chiefs awake at night: Is there any way to know before a scandal bubbles to the surface?
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