AT: You’re now the vice president and global chief compliance officer at McDonald’s, but before we get to that, I want to go back earlier in your career. You have had an atypical journey in compliance. You spent several years in compliance in the government sector. You served as the chief compliance officer for the City of Chicago and then moved over to the Chicago Transit Authority (CTA) in noncompliance roles. First, what attracted you to government sector compliance efforts?
AK: It was a fascinating opportunity to see how the City of Chicago works from the inside, and it was an opportunity to do something I hadn’t done before—which was start a compliance program in a municipal setting. Chicago was one of the first cities to adopt a corporate-style compliance program. At the time, there was a bright and energetic team leading the city’s change efforts. They were implementing the General Electric model of performance management, and compliance was an informed component of it in terms of holding people accountable.
I was approached about the CTA role by people with knowledge of the work we were doing for the City of Chicago. They thought the experience needed to oversee safety at the CTA had distinct parallels to the compliance work at the City of Chicago. The CTA needed someone to look at processes, accountability, and segregation of duties. This could mean, for example, separating people who do rail repairs from those who inspect them. It’s similar in many ways to what we do in enterprise risk management (ERM)—identify, assess, evaluate and analyze, act, report, and monitor. There’s real connectivity between safety, ERM, and compliance work.
AT: What can we learn from safety to encourage people to feel that compliance—like safety—is everyone’s obligation and that pointing out an issue isn’t a betrayal?
AK: Any time you look at a safety failure, it’s generally not one act that leads to the failure. The mistakes made by a bus or train operator, for example, are very visible. What’s not as apparent is the failure that led to that mistake. Whether it’s training, awareness, learning from past mistakes, or learning from near misses. People who work in places with a strong safety culture use after-action reviews, or incident debriefs to facilitate open discussions around root causes. This work can help identify and resolve systemic issues that can lead to safety failure.