Susan Roberts, JD, CCEP, CCEP-I, was previously Chief Compliance Officer for Hollister Incorporated in Chicago, Illinois, USA
AT: You’ve just retired from full-time corporate life, ending your career as chief compliance officer for Hollister Incorporated. We’ll come back to that, but let’s go to the start of your compliance career. What drew you to compliance in the first place?
SR: I started my career as a trial lawyer at a large law firm and then went in-house to a medical device and pharmaceutical company, where I was responsible for directing strategy for the company’s worldwide litigation. A few years in, the company discovered compliance issues in a few of its business units, so the board of directors asked me to create a centralized compliance program, and I became the company’s first chief compliance officer.
AT: Looking back, what would you like to tell your compliance newbie self?
SR: I would remind myself to breathe! Compliance roles can be overwhelming, even more so when you are in the midst of investigations and also building a team and setting up a new function. When you’re in that situation, you have to become “comfortable with being uncomfortable” and remember that everything will take time. It’s also helpful to look back every now and then to see what you have accomplished, even though there’s always more to do.
AT: Over the last 15 years, there have been a lot of changes, obviously. I remember when I first got involved in compliance 20 years ago, people were still debating whether you could do mandatory compliance programs. What do you think have been the most dramatic changes?
SR: There is so much more government scrutiny, oversight, and requirements, not just for highly regulated industries and not just in the US. These days, companies really have to pay attention and ensure that they are being compliant. I don’t believe that’s going to change any time soon.
AT: Let’s turn to some of the areas that you focused on during your career at Bausch + Lomb, Hospira, and Hollister. First, how did you balance the need for thinking strategically vs. just getting through the day-to-day tasks? And along those lines, what’s the right balance between tending to the forest vs. individual trees?
SR: As a compliance professional, you have to be strategic and also detail-oriented; you need to see the forest and the trees. You should look at the organization as a whole, where it is, where it’s going. Is your company entering new product lines or new geographies? Is it acquiring other companies? Once you’ve assessed the organization, then assess and analyze your existing compliance program. Is your existing program able to effectively mitigate the risks the organization currently faces? How about the risks the organization is likely to face in the future? If your program is not able to effectively mitigate these risks, then you need to prioritize them and determine what it is you will need and how you’re going to get there. That’s your strategic vision, and that will drive your compliance initiatives, which are the day-to-day tasks. Always keep your strategic vision in mind, however. Otherwise, you will not move forward; you’ll just be doing the day-to-day tasks.