Ronnie Kann (aaron.kann@energizer.com) was interviewed by (adam.turteltaub@corporatecompliance.org), Chief Engagement & Strategy Officer at SCCE & HCCA.
AT: Glad we could do this interview. As I started on it, I realized it was about 15 years ago now that we first met, back when you were working at the Corporate Executive Board (CEB), which is now a part of Gartner. You’ve had an interesting career in law and compliance, seeing things from a lot of different angles. What was your practice area?
RK: When I started to practice law, I worked in the litigation departments of large law firms in New York and Boston. As a junior associate at that time, that basically meant my practice area was “document review.” Along the way, I had the opportunity to learn from some of the best lawyers in their fields. These experiences improved my attention to detail, because nothing could be filed in court or sent to a client unless it was “perfect” and had passed the partner test. As my career developed, I started to expand into other practice areas, including white-collar defense, healthcare, and environmental law. Although I did not appreciate it at the time, I think that I was destined to go into compliance—I wrote my first code of conduct for a client in 1997.
AT: You then became a trial attorney at the U.S. Department of Justice (DOJ), but unlike a lot of people we talk to in and around compliance, you weren’t a prosecutor. Instead, you defended challenges to government policies and programs. I’m curious if that experience later helped you when it came to writing policies and procedures for compliance programs.
RK: That is a very interesting question. I had not thought of my role in quite that way. My time at the Justice Department profoundly influences how I approach compliance, but not in the ways I might have expected. First, what a humbling experience it is to represent the United States government. Judges, clients, and opposing counsel expect more from DOJ attorneys, and they should. I was working on behalf of something greater than any individual client. My cases often involved defending the constitutionality of laws and regulations or the legality of agency actions. Like compliance professionals, my role at DOJ was to advocate for what was right, not just what arguments could be won. In one case, we were defending an agency’s decision to limit retirement benefits to former government employees. While we had the law on our side, was it fair to the men and women who risked their lives in service to the country? That’s a discussion for another day! Second, I gained a deeper appreciation for the rule of law and regulations in driving clarity and certainty. Some of the cases were decided based on statutory or regulatory interpretation. I saw firsthand how a single word or phrase could affect tens of thousands of people. Perhaps, in answer to your question, yes, my DOJ experience did help me write policies and procedures, because each word matters—not because of what is intended, but because of how they drive employee behaviors.