Tim Stow has extensive global corporate leadership experience, expertise as a senior compliance executive, and deep experience gained as a commercial in-house attorney. He has built and led high-performing legal and compliance teams that have become centers of excellence in supporting corporate operations and initiatives across the globe.
Based in the U.S., Stow is the global head of ethics & compliance at Galderma, and in the last three years, Stow has created an entirely new compliance structure, hiring a new global team and building a fit-for-purpose global compliance program for the company.
Previously, Stow was the Boston-based global head of compliance for Takeda’s oncology business. Prior to Takeda’s acquisition of Shire, he was based in Switzerland as head of the Legal International group, where he led a team of more than 50 professionals across seven regions. Before joining Shire in 2014, he worked for UCB, where he held positions as general counsel in North America and head of legal affairs for International. Stow’s early career experience includes progressive legal positions in London, Brussels, and Philadelphia at Schering Plough and Glaxo SmithKline.
Given his extensive U.S. and international experience, we asked him to pick out three ‘fundamentals’ in terms of keys to compliance success – both running an engaged and effective department but also ensuring compliance remains very much top of mind for the businesses that he, and the many global teams he has led, have supported. This is what Tim had to say:
1. Business Ownership of Compliance
I have worked in several different companies worldwide, and all have had one thing in common - a performance-driven culture at their core. On its face, this may present a challenge to a control function such as compliance - the challenge is 'how does what we are trying to achieve and engender resonate for a business focused on performance?’ But the two can get very nicely, and in many respects, they are the key to a successful and effective compliance program.
Training is important, but having your team first spend time with business colleagues deliberately taking time out to have them gain a better understanding of the rationale underpinning any policy or guidance is critical. You are selling the concepts and, better still, how such concepts do not just sit alongside the business drivers, almost as an accommodation, but actually contribute meaningfully to the business's achievement of its goals. That's the sweet spot, and frankly, there is little or nothing that we can achieve where we haven't first applied that essential maxim to any given initiative.
And, of course, what you start to see then evolving - and this is the exciting part - is a more natural, organic, and real ownership of compliance by the business itself. In the teams I have worked in, we see ourselves as drivers and facilitators, not owners. Ownership has to reside with the business, and for compliance to be credible, it can only be this way.
They say a team is only as good as its weakest link, and as a hiring manager, that means do your absolute and level best to bring into your organization the right people.
It is too easy for compliance teams to operate as a top-down function. If that is the case, the business will quickly see it that way too. Compliance cannot be seen as the ‘issuer’ and 'publisher' of processes and policies, with everyone else in the organization as the (passive) recipient. In teams I have worked in, we always try to engage early and frequently with our stakeholders so that our output will ultimately be seen as the business’s output. When you have crossed that rubicon, you don’t just have in place a compliance program but very likely an effective one.
Indeed, the secret of the success of a compliance function is not the shininess of any new policy package but how well-understood and enacted such requirements really are. I always try to ensure that compliance support remains embedded and on the ground. Large HQ-based compliance groups can work, but the danger – and I have seen this oftentimes in the past - is that it is often difficult for such groups to resist the gravitational pull away from the business ‘coalface’. That then often gets reflected in the group being perceived as more distant, less practical, more ‘us and them’ – the antithesis to how a compliance group should be.
2. Know Your Markets
A second fundamental is to know your stuff. This sounds flip, but in the context of running a global compliance program, I mean, more specifically, 'know your markets'. Knowing how to operate and implement an effective compliance program across an organization with a genuinely global footprint will always be critical.
Very sound and thorough U.S. experience is a must, but knowledge, empathy, and understanding of other international markets are just as important. Too often in the past, although this has gotten much better, U.S.-based and U.S.-driven compliance programs get rolled out elsewhere with little or no heed taken of different market jurisdictions, cultures, and dynamics. We are back to the top-down problem I mentioned earlier.
Aside from actual language challenges, even to someone with a good command of English, U.S. legal and compliance concepts and nomenclature can often be difficult to understand. Or, worse still, jarring. Compliance principles can and should be the same - consistently communicated and applied across the world - but serious and considered thought always needs to go into how these are relayed. Good compliance groups, with effective compliance programs are the ones that get this right.
3. Clever Hiring
They say a team is only as good as its weakest link, and as a hiring manager, that means doing your absolute and level best to bring into your organization the right people. The weakest link mantra then becomes redundant and irrelevant. Of course, this is easier said than done, but in my experience, cutting corners in the hiring process will invariably come back to bite. Nothing new there, perhaps.
But a further point to consider, and something I have looked increasingly to do, is broadening the hiring pool - drawing, as best one can, from a host of different disciplines. Being an in-house lawyer for many years, this was often impossible because you needed, by definition, to hire into your team qualified attorneys. But with compliance, it is different, and you can and should look to recruit candidates with different skill sets and competencies.
The result is that you end up with a diverse mix of competencies in your team. Those with sales, marketing and medical backgrounds, for example, can bring much to a compliance team – they will invariably look at things in a different way, through a different lens. They also bring with them that invaluable commodity with the stakeholders they support - credibility. And credibility, as you will appreciate, is pure gold in this context.
