In-House Interview: Aslı Ertekin, Ethics & Compliance Manager, BP

After graduating from Hacettepe University's Department of International Relations in 2004, you received your master's degree from Ankara University's Department of European Union and International Economic Relations. You have been continuing your career at BP for nearly 17 years. Tell us about your professional background and aspirations.

Let me first start by thanking Turkish Law Blog very much for this opportunity.

While I was studying at the university, my goal was to become an academician, however, I also told myself that I shouldn’t be closing the doors to other options. It was one of the advantages of studying international relations which is interdisciplinary in nature, blending the fields of economics, history, and political science to examine topics such as human rights, environment, economics, globalization, security, global ethics, and the political environment. In those years, ethics & compliance (E&C) as a profession was not widely known, at least in Turkey, therefore I should say that this wasn’t my ultimate career aspiration. Nevertheless, today I feel like I wouldn’t have enjoyed any other job like I do in E&C as it's so aligned with my character and life purpose.

In 2006, you joined BP as a Contracts & Procurement Assistant and continued your career as an Ethics & Compliance Officer in 2013. As of September 2022, you are currently working as Ethics & Compliance Manager for BP Mauritania and Senegal Region. What inspired you to become an ethics & compliance professional?

An opportunity at BP came up when I was continuing my master’s degree in 2006. It was only a temporary short-term job in the contracts & procurement department and I saw it as a good opportunity to meet the corporate world. After 6 months, the company offered me a permanent role in this function where I worked as a contracts & procurement specialist for the next 7 years. Working in the procurement function may expose one to higher ethics & compliance (E&C) risks so, I was so eager to understand these risks, the company’s rules and the code of conduct. As I became more aware of the E&C risks and the culture, my interest for the E&C as a profession got increased. Fortunately, a vacancy as ethics & compliance lead for BP Turkey appeared which I applied for and got accepted in 2013. I worked in this role until 2018 when I moved to a regional ethics & compliance lead role, responsible for Azerbaijan, Georgia and Turkey. And in 2022, I moved to another region in BP as the ethics and compliance manager. For me, developing and overseeing programs that reduce the risk of illegal or unethical activities in the company and inspiring & guiding people to do the right thing is the main motivation to work in the E&C field.

Given your prior experience, do you believe a law education is required to become an ethics and compliance professional? How can having a law background help in the role of ethics and compliance?

Typically, a bachelor's degree is the bare minimum education a compliance officer must have but there is no specific compliance officer degree. In many cases, people looking to pursue a compliance officer career may earn a bachelor's degree in legal, finance, economics or business administration.

In many global companies, E&C roles are not under the legal discipline, instead, they are formed as independent functions, ideally reporting to the company’s board of directors. In fact, compliance is often not technically a legal role, and E&C professionals typically do not provide legal opinions or represent their firms. Although it is absolutely not a must, as you may also see in my case, I believe law education might be an advantage to work as an E&C professional. As effective communicators and problem solvers, lawyers can leverage their legal training and knowledge in compliance as, for example, you need to understand how laws like the Turkish Criminal Law, Foreign Corrupt Practices Act or UK Bribery Act work before you can determine whether your company’s programs adequately address those risks.

What personal and professional qualities have you found to be most useful in your role as Ethics & Compliance Manager, Mauritania and Senegal Region at BP? In your opinion, what are the criteria for a successful ethics & compliance manager?

I think the most critical quality for an effective E&C officer is understanding the organization’s level of risk tolerance and be able to assess alternatives and make sound decisions based on the potential for risk. Listening skills and showing empathy for the business and other functions has played the most important role in my success as an E&C professional. Of course, it goes without saying that a compliance officer needs to have integrity with strong moral principles, fairness, and honest desire to do a good job.

Successful compliance managers should also have strong communication skills, ability to interpret business priorities/ sensitivities, ability to apply rules to real-life facts, analytical and critical thinking, proactiveness, time management, focus on continuous improvement and ability to manage conflicts.

What do you believe the ethics & compliance professional's role and value should be in an organization for a successful and sustainable business?

I believe the role of ethics & compliance is rapidly developing, opening up new and increasing opportunities across a range of sectors. E&C professionals play a key role for protecting company’s reputation, building a long term and sustainable future and increasing the value of the company’s brand.

This is mainly because each player in today's business world now accepts the purpose of existence of companies is no longer just making profit and excluding their competitors in the sector. In this context, it is becoming clear that companies that provide social benefits come to the fore in the dynamics of the business world. The traditional model of doing business is increasingly being replaced by a business understanding that puts people and society in its focus, realizes that it is a whole with the environment, has thoroughly internalized the ethical culture, and covers all the stakeholders of the business world. Companies which do not see this or do not want to see it, on the other hand, should expect reputational and financial losses in the future.

Since April 2021, you have served as Chairman of the Board of the Ethics and Reputation Society (TEİD). How do you see the future of compliance and what do you think it takes to be a successful ethics and compliance professional?

TEİD is the reference point for private sector companies in Turkey for developing and implementing the internationally recognized business ethics principles within Turkish business environment. Since its establishment in 2010, TEID has been playing a very critical role for cultural change in the Turkish private sector and educates compliance officers who will effectively manage integrity risks for their companies. With its 200+ corporate members (with a total yearly income that exceeds 15% of Turkey’s GDP, employing more than 800.000 employees) TEID created Turkey’s biggest cross-sectoral collective action initiative with signing TEID Declaration of Integrity. I feel very proud to serve as the Chairperson of the Board of TEID for the last 2 years and will handover my role in the next ordinary general assembly at the end of March 2023.

With regard to the future of compliance, both my roles in TEID and BP showed me that the importance of ethics and compliance is ever growing. While the importance given to ethics and compliance programs has increased globally since the 2010s, ethics and compliance management positions have become indispensable for companies in order to avoid major penalties and loss of reputation. Future for ethics and compliance professionals seems to be very bright as the recent global developments proved that ethics should be in the heart of anything we do. Above all, values, integrity, and compassion are the drivers that can make the world a better and more inclusive place.

We should all recognize that technology allows us to function with a complexity that didn’t exist when many regulations were put in place, and it creates many questions of practical applicability. As regulators adopt more rules to adapt to this new environment, where we face increased levels of data collection, usage of artificial intelligence, complex computer programs etc, there is a greater need for compliance employees to ensure that a business is in line with expectations. So, the job description for E&C professionals isn’t getting any shorter. Professionals in this field must be prepared to continuously improve, be curious, creative, tech-savvy, and data-driven.

BP positions itself as a globally integrated energy company. In this direction, it carries out various projects that also affect ethics & compliance processes. Can you tell us about your role as ethics and compliance manager in a global company?

As one of the world’s leading energy companies, we take our responsibilities seriously. Our own people, the communities where we operate and our customers all expect us to observe the highest ethical standards. We’ve set a new purpose and ambition – to reimagine energy for people and planet and to become a net zero company by 2050, or sooner, and help the world get to net zero.

To achieve those goals and drive value through the energy transition, we’ve defined a new strategy and reorganized the company. Now we are introducing ‘Who we are’ – which we believe will help us create an environment that encourages and supports everyone to perform at their best. bp’s code of conduct is our guide to doing the right thing. It’s at the foundation of ‘Who we are’ and everything we do at bp – from the boardroom to the front line – and highlights our absolute commitment to safety, ethics, compliance and speaking up. Having one set of beliefs and clear expectations in our code helps us make choices in a consistent way, around the globe, in many different contexts. Each section of the code is set out clearly for everyone – wherever they work.

As the company’s E&C liaison tagged to a specific region, I’ve always seen my key duty as building a bridge between the global strategy & expectations of the company and the regional business needs. It’s important to tailor the group requirements and messages to the local realities/culture. My focus has always been understanding the specific risks relevant to the business/jurisdiction, having open communication, building trust, reviewing the data to analyse the trends and helping each stakeholder to proactively mitigate the risks.

What are the international and ethics & compliance risks trends in the energy industry you expect to impact the Turkish market the most?

Energy industry operates in a complex and dynamic environment, therefore it is essential for companies to adhere to the highest ethical standards. The energy industry has always been under scrutiny for its practices and operations, particularly concerning anti-corruption, ethics, and compliance. The industry’s impact on the environment and society and its close association with government policies and regulations make it a prime target for criticism and calls for greater transparency and accountability. Ethics in the energy sector can include environmental protection, human rights, and responsible resource development. Compliance with laws and regulations is critical for the energy industry, particularly regarding environmental protection, health and safety, and anti-corruption. Companies in the energy sector must comply with a complex web of local, national, and international laws and regulations, and non-compliance can result in significant penalties and reputational damage.

New international E&C risk areas are emerging every day in ESG, whistleblowing, supply chain, data protection, and many other areas. I expect the third party E&C risks in the supply chain to be the most impactful one. E&C professionals cannot be subject matter experts on all topics, but they are expected to know how to build and develop bench strength. For that purpose, I have been focusing on anti-bribery and corruption risk management in the supply chain and actively working in TEID’s third party risk management working group, which has recently published a very useful guide and continues its efforts to increase awareness around this topic.

When you look back at your career, what lessons would you share with your younger self?

Find and follow your passion, keep your enthusiasm, never be afraid to ask questions and stepping out of your comfort zone, care about the work/life balance and be kind to yourself.