Jo Morgan - Group Chief Compliance Officer, IMI PLC
What first made you decide to make the move in-house and why did you do quite early in your career ?
I always wanted to gain some in-house experience with a view to understanding my clients better. I thought I would do a couple of years and then go back into private practice. I decided to do it early for that reason, so there was still time to come back to private practice and not have missed out on too much of the advancement towards partnership. However in-house was way too interesting and I never went back!
Do you think there is an optimum time in a lawyers career to make the move in-house?
I would of course say the earlier the better as it has really worked for me, but there is something to be said for getting more of a grounding in a law firm before you make the move so I would probably say 3-5 years qualified is about right. At that stage you know enough to be good but you are not too set in your ways and can still become a business person first and lawyer second which is critical for successful in-house work.
How many lawyers were in the IMI legal team when you started?
Three including me! It was very small for the size of company.
How has it grown since then and why?
Yes there are now around 20 legal and compliance folk worldwide. That is a response to the increased importance of compliance work in the company as a result of heightened legislative requirements, and the desire of our divisions to have their own lawyers based in the divisional head offices for the day to day work.
How has your career developed within IMI?
Well when I started I was the junior lawyer (or as we termed it Assistant Company Secretary in those days). I got the chance to work on so many different areas from M&A to employment law to share schemes and of course my first love: Commercial contracts and it was a great grounding in in-house practice. From there I was promoted to the Deputy Company Secretary role which was the second most senior legal position in the company and this afforded me the opportunity to work on more complex matters such as regulatory investigations. I am now independent of the legal team and heading up my own worldwide Compliance department which is very exciting.
Why did you decide to make the change into the compliance arena?
It’s fascinating! I love the opportunity to set standards and be at the forefront of an emerging area of law. There is so much variety in the type of issues we deal with and I really like trying to understand why something has gone wrong, particularly trying to understand human behaviour which caused the issue. I also like the communication piece of my role as that gives the opportunity for me to exercise my creative side. We’ve done poster competitions, parody songs, and showcased our products through film and music. It’s great fun!
What is your role as Group Chief Compliance Officer?
It is really being the conscience of the company. It is my job to set the standards of behaviour expected and assist in the promulgation of them. I am responsible for the Code of Conduct, the whistleblowing hotline, the anti-corruption programme and all ethical matters which affect the company, this includes doing some fairly hefty due diligence on target businesses so I still get to dabble in M&A.
What is the size of your team?
I have 12 people worldwide: three in China, one in Russia, four in the UK and four in the US. I expect the team to grow by one or two in emerging markets between 2013 and 2015.
Do lawyers misunderstand the role of compliance?
Absolutely! Most lawyers think that we are box ticking monkeys! They could not be more wrong. The way my team operates is as a real business partner, solving some of the most thorny issues that the business faces whether those issues are internal or external to the company. It really is a business critical function and no-one comes to Compliance if it is easy, so the intellectual challenge is immense!
Is there a better word to use for what you do than compliance – the word seems to have a negative effect of lawyers interest in a role?
I have always prefer the term “Business Integrity” – it says more about what we do. We try to keep the business whole and we want to encourage all of our people to do the right thing, always, as this brings about real tangible benefit for the company. If we all do our jobs to the best of our ability with the highest of integrity then the overall company is much improved as a result. IMI’s results over the past three years bear this out.
What has been your greatest effect on the company so far?
Introducing our Code of Conduct (The IMI Way) in 2009 and a yearly all employee face to face international training programme to support it. The IMI Way has been the biggest single factor in changing the culture of the company and bringing about real competitive advantage where we are able to sell on our ethical credentials and the fact that by doing business the right way we ensure that our business is sustainable.
Would you move back to a general counsel role?
Yes I could see that as my next move. I still enjoy the pure legal side of things and I have Compliance and Company Secretarial skills in my toolkit too so I probably should make use of all of those skills and a GC role would seem the most appropriate way to do that.
