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Leveraging Policies and Culture: A Recipe for Success

Anti-Corruption Report

In this article, Ann Sultan, Member at Miller & Chevalier, and Anna Romberg, Executive Vice President of Legal, Compliance and Governance at Getinge, explore the tension between a rules-led and a culture-led approach towards ethics and compliance based on their experiences working with U.S. and European companies. Neither culture nor policies exist in a vacuum and, if used effectively, can strengthen each other. "The key is to be explicit about the roles that both a company's policies and its cultural values have played in making key business decisions." the authors wrote.