How to Approach a Compliance Program: A Q&A With a Former Fortune 500 Director

How to Approach a Compliance Program: A Q&A With a Former Fortune 500 Director

Outdated compliance programs are a dime a dozen. What was once considered leading edge has now become a basic expectation — yet many of our programs are four times as old as our mobile phones.

I spoke about the modernization of compliance programs in my keynote speech, “How to Approach a Compliance Program”, at the Supply Chain Summit Series event in San Diego last week. My presentation focused on approaches to compliance, leadership and stakeholder expectations, implementation, and automation.

Conference attendees were given the opportunity to ask follow-up questions about my presentation and my experience as a former director of global Environmental Health and Safety (EHS) and sustainability at Seagate. This blog features those questions and my responses.

Why are product compliance declarations still such a struggle for suppliers?

In my opinion, it comes down to supplier fatigue. Suppliers face a myriad of customer requests, and companies do not follow up on many of them. Due to the perceived lack of importance, suppliers may wait to see if new data requests are genuinely required before committing resources to the response.

Supplier fatigue also stems from the need to reformat data for different customers. This isn’t just data mapping — the information requested is often significantly different and requires additional resources. Suppliers understandably push back on these requests. This is why aligning requirements with standards is critical for supplier compliance. Consistency over time reduces supplier fatigue, and even relatively small, incremental changes in reporting requirements can make compliance difficult for suppliers.

How do we better educate sub-tier suppliers on product compliance to reduce the amount of time we spend on quality control?

First, we need to get over the idea that each company must develop a unique approach, with unique compliance and data requirements. If we better align with industry standards and requirements, we reduce supplier fatigue. Secondly, we can improve supplier training and education by leveraging low-cost approaches such as online training and webinars.

How do you deal with suppliers that are non-responsive to your requests?

I have several best practices to engage suppliers, which include:

  • Finding the right contact points. Some supplier marketing or sales representatives don’t understand how to properly respond to a request.
  • Clearly communicating requirements and their importance, and assisting with training and help desk support to enable the supplier to respond.
  • Getting feedback to improve compliance systems.

Of course, some suppliers simply won’t respond or comply. This creates a significant business risk for you and your customers. This will require time-consuming escalations, and can eventually result in the supplier losing your business entirely. This should be a very rare occurrence.

In your previous role, what was the ‘“aha moment” that led to your buy-in for a modernized compliance program?

I saw a spreadsheet-based records system that was difficult to mine and provided inconsistent data. When this was combined with constantly changing customer requirements, it became quite expensive to maintain, so it was really a no-brainer to develop a more cost-effective approach.

I also aligned the program with industry standards, leveraged useful software tools, and implemented well-documented processes and clear organizational roles — all fundamental changes that prepared us for future compliance challenges.

What savings were you able to achieve when you adopted a modernized strategy for your compliance program?

If the right standards, IT systems, resourcing models, organizational structures and processes are put in place, savings can top 40 percent.

What separates an average compliance program from a great one?

It’s important to not confuse great marketing with great compliance programs. A truly great compliance program is about more than just an annual sustainability report — it’s about building highly-credible data with cost-efficient and resilient compliance. Leading programs don’t just satisfy stakeholders — they delight them. If you establish leadership, your customers and other stakeholders will come to you first when they face new challenges.  

I think many companies mistakenly focus on differentiation to get credit for compliance program leadership. This can result in good marketing collateral, but it defeats the resource efficiencies and the real global progress of compliance programs. Leadership means helping others through collaboration, not dissociation.

There are many approaches to building effective strategies and implementations, but start with examining stakeholders and their requirements, how those are likely to change over time, and what will really delight those stakeholders. This helps set the goals that will guide your overall strategies.


In his most recent position with Seagate Technology, Brian Martin managed global EHS and sustainability. He was responsible for all aspects of Seagate’s environmental and sustainability programs, as well as its global occupational health and business continuity programs. Brian has worked in a variety of roles, including research and development, sales and marketing, supply chain management, finance, and service supply chain. In addition to Seagate, he has held positions at IBM, Akashic Memories, Phase Metrics and HGST.

The Assent Compliance Platform can help modernize your compliance program. To learn more about Assent’s supply chain data management software, contact info@assentcompliance.com. To stay up to date on webinars, regulatory news and events such as the Supply Chain Summit Series, subscribe for updates.

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