Mark This! Episode 37: Culture of Trust
Host: Heather Dotchel, Corporate Communications, Aramark
Guests: Tamsin Fast, Chief Compliance Officer, Aramark
It is time to mark this, a podcast in which we peel back the corporate curtain to reveal the cool and innovative people, programs and projects that are happening all over Aramark's varied lines of business. I'm Heather Dotchel. As a member of Aramark's communications team, I see and hear amazing things that are happening across our company every day. These remarkable initiatives happen because we have remarkable people behind them, building opportunity, building innovation, and building community. Aramark as an enterprise just accomplished a major internal milestone, 100% completion of compliance training by the deadline for tens of thousands of employees. If you've ever managed a project with thousands you know how impressive that is. Now, yes, I hear you all in the audience thinking, compliance. This podcast is supposed to focus on the cool and the innovative, but this falls squarely in those categories.
The prioritization of compliance training, including business conduct, anti-corruption and political contribution policies sits at the core of Aramark's trustworthiness as a partner and employer. It sets a tone that all employees from the C-suite to the front line are expected to understand, follow and respect the rules that make sure that Aramark is grounded in an ethical outlook, ethical business practices, and ethical interactions with each other. And that is definitely cool. Now let's dig into the program and learn about how its innovation has driven compliance with compliance. Tamsin Fast, chief compliance officer, is joining us today to dig deeper into this culture, a culture of trust that is only achieved through years of making sure that compliance truly matters. Tamsin, welcome to Mark This.
I'm so excited to be here, Heather, I just hope we can live up to your expectations of being cool and innovative.
I have no doubt that that will happen.
More seriously though, I'm really excited to be here to really help explain the why behind our compliance program, and also to recognize all the amazing work that Aramark team members are doing every day to earn the trust of our clients.
I'd like to start by asking, why compliance? What path brought you to this role today?
I will be the first to admit that when I was asked as a little kid what I want to be when I grow up, I was never like, oh, compliance. In fact, I didn't even really know what compliance was. Even in law school, they didn't talk about it. I am an employment lawyer by background, and so I've practiced employment law at a big firm before coming to Aramark almost 19 years ago, which is crazy. And so I led our employment law team for 10 years, again, really just managing and overseeing government investigations and employment law litigation, but then also started to get involved in ways to make things easier for the company to comply with the law.
I led the creation of our wage and hour compliance program, which is basically a program to make sure we pay our employees correctly. And also I led the creation of our background check compliance program, which also very important. And I really enjoyed that work, and so I was super excited when I had the opportunity to be considered for a role where I could do compliance all the time. I've been in this role for almost nine years. I oversee our global compliance program, so for the whole company across our 16 countries, and I report to our general counsel and also to the chair of the audit committee of the board of directors.
Again, I'm always impressed by the scope of jobs that guests on Mark This have when you are in a huge global company and you have so much to be responsible for, it's pretty amazing. But when we talk specifically about our legal teams and in this case compliance, I do have a question for you, Tamsin.
How do you sleep at night?
Well, given the breadth and size of Aramark, I actually get that question quite a bit. Leading a global compliance program would be an impossible job if it was at a company that only pays lip service to integrity and doing the right thing. At Aramark doing the right thing is embedded in everything we do around the world at every level of the organization. We have a culture of trust and our senior leaders set the tone and lead the culture by example every day. And our 265,000 team members live that culture, so I do sleep at night because we're a people company and our people are focused on integrity and doing the right thing every day.
Good to know you sleep at night, but why have a compliance program? Why not just trust that trust will be established?
That's a great question, Heather. First, it's obviously the right thing to do to make sure that you've got that structure and commitment in place to comply with the law, but it's also a baseline expectation that every company will have a compliance program to comply with the law and also avoid penalties and reputational harm. Some people think of compliance as something that gets in the way of being profitable, but I think they really couldn't be more wrong. Compliance is good for business and directly contributes to protecting and maximizing shareholder value. And this is particularly true in our business when we provide services to our clients in their spaces. What we do reflects on them, and we are very aware of that, so when they choose Aramark, they're trusting us and we must earn their trust every day.
Is there a blueprint for what a compliance program should look like?
Not exactly a blueprint, but there are guidelines from the U.S. Department of Justice that lay out what an effective compliance program should look like. By way of background, companies actually can be criminally convicted, believe it or not. And a point of the compliance program is to do everything possible to prevent a violation, so you have all of those, the structure and the checks and balances in place. And the idea is that if there's a bad apple or rogue employee who goes and does something bad and the DOJ is looking at the company, the idea is that the DOJ will consider the effectiveness of your compliance program in reducing what might've been a multimillion dollar fine or even deciding not to prosecute the company. It really depends though on the type of company. And so it's not like there's a checklist or a blueprint, it really has to be based on how the business operates.
I know one thing that always strikes me when I go through my compliance training every year because thank you very much, I'm always months ahead of the deadline, is the fact that not knowing doesn't protect the employee. You have to be aware. You have to make it your job to understand this. And that always sits with me when I go through the compliance program.
Super important. Ignorance is not a defense. The law is the law. The policies are the policies.
And it makes a program like this all the more important because now I know. Anyways, tell me about Aramark's compliance program specifically. What's innovative about our program?
Well, starting with overall, before I get into the innovation part, from a bread and butter standpoint, we have our business conduct policy, which is our company's code of conduct, which guides everything we do. We have it in 11 languages. And then of course we do have the training that you referred to that we deliver online to our salaried employees, that's 27,000 around the world in all those different languages. As well as training and guides to help our front-line associates who are not necessarily online, so that's a really important part of the kind of bread-and-butter aspect of our program, the education and making sure that what we're educating on is relevant to a person's job. In addition, we have a risk assessment process, which I think is quite unique. It's called compliance council. Our compliance council meets quarterly, and it's been really since the beginning of the compliance program a couple of decades ago that was started where we have stakeholders from around the company that meet and we choose three or four compliance risk areas for the program owners and or risk owners to talk about.
And it's very deliberately not supposed to be a rah-rah type of presentation. It's much more of a discussion where we ask hard questions and make sure that we understand whether our risk mitigation efforts are sufficient and is there something we're missing, so those are bread and butter. But there are two aspects of our program that I believe are truly, truly unique. First, earlier I mentioned culture and our culture of trust really is the foundation for everything we do. We talk a lot about our hospitality culture. We are delivering exceptional hospitality experiences to our clients every day, so our clients do see our kindness, collaboration, and empathy every day. We also have a culture of trust because, and it really kind of overlaps, we're making sure that what we do is the right thing to do and also meets the expectations of the client because they know that what we do reflects on them and it sets the tone for everything we do.
A culture of trust also means making sure that everybody understands that we're all in this together and everybody's treated the same. There isn't a situation where the rules only apply to certain people. Our culture of trust is our culture externally with our clients and also internally. One example is our CEO, John Zillmer. Oftentimes I'll go downstairs and see John waiting in line at our cafeteria for one of our amazing salads or pizzas or local restaurant offerings. And he's just waiting in line like everyone else, which I think sends a real message in modeling, the rules apply to everyone. Another example is Marc Bruno, our US COO, who like everyone else waits in line. Well, for those people who have the courage at the Polar Plunge, which is a charity event to raise money for the Special Olympics. He's standing there in his bathing suit in freezing cold February weather with everyone else and then jumping into a pool of freezing water. These are leaders who are just normal people, and I think that really permeates and makes a huge difference from a tone from the top standpoint.
I agree there's not... I'm also based in headquarters, there is not a day in the office where I do not run into and organically have conversations with those in the C-suite. Everybody is available and it is very much a team atmosphere at all times.
And look, the reason I put this into the category of innovation is you can't just decide one day, oh, we're going to have an ethical culture. This is something that is built over decades. And so I do think that this is highly unusual in today's times and it sets us apart, so it's innovative in a what's old is new kind of sense of things. And I do think that it's one of the many reasons that so many of us have stayed at Aramark for so long.
And I will also interject here. I've said many times, I think in this podcast over the years, it's one of the things that really inspired me to start this podcast is that amazing internal culture that we have at Aramark.
The second unique aspect of our compliance program is our laser focus on the field. The vast majority of our employees are not sitting behind a desk. These employees are the ones who are out there in our client spaces delivering exceptional hospitality experiences and doing things like reviewing inventory, scheduling team members, hiring, onboarding and training new team members, planning menus, answering a question from a student about allergens, meeting with the client about a special event that's coming up. They want to do the right thing, and it's our job to make compliance as easy as possible, so there has to be a laser focus on them.
In conversations that you and I have had in the past you have expressed to me how important it is for your team to have operational experience, so can you talk to me about that a little bit and how that helps to make our program more field friendly?
A unique aspect of our compliance team is I always make sure we have former operators on the team because they're the ones that really understand the experience of somebody who's in the field and understand what their priorities are, what their perspectives are, and they know how to simplify in a way that is understandable by our operators, so that is absolutely critical. And frankly, they also have that credibility when if there's something that really needs to be done, it means a lot more when you have somebody with 20 years of field experience who used to be working side by side with you saying, hey, look, I know you're super busy, but we really need your help with this, or whatever it is. That is something that I think is very unique in talking with my peers, with other companies, having somebody with this field experience.
And actually what I would say is it's been amazing because this has been really now going on for a couple of decades. And so we have now a history of compliance team members who have moved on to senior leader roles. I'm not aware of any other companies that have a true focus on sourcing team members who have operational background. They're typically looking for legal or compliance backgrounds. And I do think that this is what sets us apart and makes us more likely to be effective because we really have insiders basically on the team who know what needs to be done and how to interact with the field.
Let's talk some real world examples. Longtime listeners know that I always like to bring our discussions back to the concrete. What are some everyday examples of our operators living our culture of trusted hospitality?
I would love to share some examples. Our operators do amazing things like truly, truly amazing. First, food service is at the heart of what Aramark does, and so food safety is absolutely critical. Last year we served millions of meals globally and we did so safely. And that isn't easy to do. There is special training that happens, certifications, it's an awesome responsibility for us.
It really is. Our safety teams are incredible. I work with them frequently, and I am just always ultra impressed with their speediness, their humanity and their service.
Another example of our operators living our culture of trusted hospitality is our sports and entertainment business and our professional sports stadiums in the U.S. And our alcohol compliance program is really, really important, so when we're ramping up to football or baseball or whichever professional sports season, our operators on the ground are making sure that every person who serves alcohol has completed their alcohol service training. Our frontline workers are trained on policies relating to checking IDs, limiting the number of drinks per person per transaction, looking for visible signs of intoxication. We want the speed of service to go quickly so the fans can get back to enjoying the game but safety does come first.
And to ensure that we have checks and balances, not only do we have all of what I just described, but there are also dedicated alcohol compliance supervisors. And then we also have a mystery shopper program, which is basically using a third party for validating whether or not our program is working. And so it's like youngish looking people who go and try to ask to be served more drinks than they should, and looking to see whether or not they're being carted. It's just amazing what our sports entertainment team does, and I'm super proud to share that in our professional sports venues we were not cited for a single alcohol violation last year. Again, just an absolute testament to the hard work that our people put in every single day.
Let's talk about how well the program is working. How can you be sure? I stole the headline at the top of the podcast by mentioning the 100% completion by deadline training results this year, so tell me more.
You're asking the right question, Heather, because it's one thing to think you have a good program, but how can you really know that it's working? And you don't want something bad to happen and then learn that something could have been better, so at Aramark, we do have ways that we are assessing our program, whether it's a periodic review with a law firm to review and validate the strength of our program, our amazing audit team doing cash and anti-corruption audits. We also look at hotline calls, which are a really important part of our compliance program. We get a healthy number of them, which is consistent with companies of our size and type. And that is a real indication of good culture because it means that people feel comfortable raising concerns and they feel free from retaliation. Absolutely critical. And we also get a lot of questions from the business that go to the compliance team and legal team, which are really asking for advice and wanting to get input.
I think the strong relationships with the business units that we experience, and this sort of interaction shows that the channels of communication are open. Those are all ways that we are able to assess whether the program is working. And then of course, there's 100% compliance training metrics. Look, we are very pleased with these results. We're referring to three courses, business conduct policy, anti-corruption, and Foreign Corrupt Practices Act and political contributions. There is no question, and as I think you mentioned earlier in the podcast, that compliance training plays a critical role in preventing misconduct, and we have to educate our employees on legal requirements in our policies as well as knowing how to report an issue if they see something and training mitigates risk for the company. But at the same time getting to 100% is table stakes.
There are other companies that get to 100%, so the reason why we're so excited about our 100% is that we set a deadline of August 31st as a company, and we literally had every single employee in the learner audience take that training by that date. Other companies, they might set a deadline, but then they're chasing a bunch of stragglers to get to 100%, and that's something that we didn't need to do, so the 100% that we achieved across these three courses is a clear indication of our robust culture and leadership. 27,000 salaried employees, 16 countries, multitude of settings, truly amazing that we're able to accomplish that. We set a goal, we achieved it. The 100% is a big deal because it proves that at Aramark, if we say we're going to do something, you can trust us that we will do it.
Want to know more about Aramark's culture of trust? Visit our newsroom on Aramark.com to access more information. Tamsin, thank you for shedding light on our compliance program and how it sets Aramark apart. Mark This listeners, thank you for tuning in.
