Carnival beefs up internal ethics and compliance team

Written by Nick Blenkey
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eter Anderson, Carnival Corporation’s chief ethics and compliance officer

Carnival Corporation & plc (NYSE/LSE: CCL; NYSE: CUK), has announced seven new hires and internal promotions as part of the development of its new companywide ethics and compliance function, first announced in August 2019 and led by Peter Anderson, chief ethics and compliance officer.

The additions include three new corporate compliance leaders reporting directly to Anderson, who is building an extensive ethics and compliance program to drive a culture of compliance, learning and integrity inside the corporation and across its nine global cruise line brands. More specifically, the goal is to meet or exceed all legal and statutory requirements and promote the highest ethical principles.

“This new team underscores our commitment to ethics, compliance, the environment and health, safety and security,” said Anderson. “We are in the process of developing a world-class, enduring culture of compliance among every one of our 150,000 employees. Compliance and ethics is at the heart of everything we do. The leadership, experience and passion of this very talented and determined team will play an instrumental role in our mission.”

To promote full integration and teamwork around ethics and compliance throughout the entire corporation, these leaders will also work closely with other newly-selected leaders who are based within the various operating companies.

The ethics and compliance team leaders include:

Kelly Clark – Senior Vice President, Deputy Chief Ethics & Compliance Officer

The deputy chief ethics and compliance officer will support the overall implementation of the ethics and compliance program with primary responsibility for interacting with the company’s cruise line brands to maintain open communications, as well as monitor local program implementation.

In this capacity, Clark will also prioritize the ethics-focused elements of the ethics and compliance program, working across functional lines to understand and support existing program processes. She will also advocate for new systems and processes to improve program oversight, and will be responsible for spearheading other important program initiatives.

Under Clark’s stewardship, Holland America Line and Seabourn – two Carnival Corporation brands currently organized under Holland America Group – have received Ethics Inside Certification since 2011 from Ethisphere, the provider of independent verification of corporate ethics and compliance programs. Ethisphere awards Ethics Inside Certification exclusively to companies that demonstrate the existence of a superior employee and leadership culture that promotes ethical business practices. Ethisphere also recognized Holland America Line to its World’s Most Ethical Companies list for five consecutive years, from 2011 to 2015.

Clark previously served in various roles for Holland America Group, including as vice president, counsel and special advisor to the CEO; chief ethics officer and general counsel; and senior vice president, safety, environmental and regulatory services. She also worked as general counsel and chief ethics officer for Holland America Line and Seabourn.

Chris Donald – Senior Vice President, Environmental Corporate Compliance Manager

The environmental corporate compliance manager oversees and implements all legal obligations in Carnival Corporation’s Environmental Compliance Plan (ECP) as well as works with the independent parties conducting oversight and analysis of this plan. In addition to leading the environmental efforts within the brands, Donald is responsible for:

  • driving improvements in waste management, technology and design (including food waste).
  • establishing, monitoring and assessing key performance indicators for environmental compliance.
  • overseeing the Environmental Officers who provide onboard environmental compliance oversight on all of the company’s ships.
  • driving and evolving the company’s Operation Oceans Alive program designed to foster a culture of compliance, learning and ocean stewardship.

Since joining Carnival Corporation in 2007, Donald has held a number of key positions that will help him carry out his increased responsibilities. More specifically, he has previously supported the company’s policy development, internal audits and investigations. Prior to his role in environmental compliance, he was also corporate senior director, safety and occupational safety, and led the company’s Engine Room Fire Risk Mitigation program, which included the design and rollout of extensive upgrades to fire detection and suppression systems across the company’s global fleet.

Gerry Ellis – Vice President, Health, Safety and Security Corporate Compliance Manager

The Health, Safety and Security (HSS) corporate compliance manager must ensure the regulatory compliance and effectiveness of the company’s global HSS programs, as well as monitor the Maritime Policy and Analysis department to maintain compliance with applicable HSS-related policies and procedures.

Ellis has more than 40 years of industry experience, including over 23 years with Carnival Corporation. He served at sea for 18 years in a range of positions from deck cadet to captain on a variety of ships, including tankers, containerships, ferries, private yachts and cruise ships, in addition to shoreside management positions, including maritime investigations director, marine operations manager, port operations manager, director of port development, director of compliance, director of shipbuilding and design, director of safety policy; and vice president, marine and technical operations.

Martha de Zayas – Vice President, General Corporate Compliance Manager

Among the three corporate compliance managers, this position has the broadest range of compliance topics to oversee, including:

  • codes of conduct, anti-corruption, anti-trust and anti-retaliation.
  • conflicts of interest, third-party due diligence screening and economic sanctions/
  • Office of Foreign Asset Control screening.
  • North America data privacy and records retention.
    Americans with Disabilities Act shoreside and shipboard programs.
  • the corporate Compliance Reporting Hotline program.

De Zayas joined Carnival Corporation in 1995 as associate general counsel, managing commercial and employee-related litigation. Since March 2018, she has served as vice president of ethics and compliance.

Sandra Rowlett – Vice President, Incident Analysis Group Investigations Leader

As the Incident Analysis Group investigations leader, Rowlett is responsible for all efforts to investigate certain Health, Environment, Safety and Security (HESS) issues – including near misses – independently of the brands. She also manages the recently expanded team of nine investigators, and assists in improving the investigative functions throughout the entire organization.

For 28 years, Rowlett held various positions within the National Transportation Safety Board (NTSB), including air traffic control investigator and senior executive with oversight of aviation, railroad, pipeline and hazardous materials investigations. Before joining the NTSB, Rowlett was an air traffic controller for Los Angeles International Airport and the United States Air Force. She reports to Ellis.

H Jordan Weitz – Senior Director, Compliance Risk Management Leader

As the Compliance Risk Management leader, Weitz is responsible for developing a more proactive and strategic focus to the company’s compliance programs grounded in data analytics, metrics and compliance risk assessments. Weitz has more than 20 years of experience, including 17 years in the cruise industry, covering all aspects of risk management including processes, risks, controls, audits, investigations, digital forensics and proactive analytics. He is also a certified fraud examiner. Weitz reports to Clark.

Brigett Potts – Director, Compliance Training Leader

As the Compliance Training leader, Potts is responsible for reviewing and summarizing all current compliance training relating to the areas within the ethics and compliance function and program to:

  • develop a corporate compliance training strategy and plan.
  • measure training effectiveness.
  • introduce new and innovative compliance training tools.
  • implement basic ethics and compliance training for all employees.

Potts joined Carnival Cruise Line in 2017 as the Environmental Regulatory and Operating Line Training Manager (OLTM). In October 2018, she became chairperson of the OLTM group, where her leadership exemplified a passion for training as she led process change across the organization. Prior to joining Carnival Cruise Line, she was an associate attorney handling cases in both federal and state courts. She reports to Donald.

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