University of Arkansas

Walton College

The Sam M. Walton College of Business

Season 4, Episode 9: Andy Ruben - Trove & Creating More Sustainable Brands

October 28, 2021  |  By Cindy Moehring

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 In this new episode of the BIS, Cindy Moehring chats with Andy Reuben, the first Chief Sustainability Officer at Walmart and the CEO/founder of Trove, a white-label platform that helps companies resell their products and create a sustainable circular economy. Hear Reuben and Moehring discuss everything from why ESG has emerged so strongly, what makes Trove successful, and the cycle of circular shopping.


Resources From the Episode

Episode Transcript

0:00:00.0 Cindy Moehring: Hi everybody. And welcome back to another episode of the BIS, The Business Integrity School. And today I am really super excited to tell you that I have a very old colleague and friend who's with me here today. And not old in terms of age, I've just known him for a long time. Andy Ruben, it's so nice to see you again. How are you?

0:00:17.4 Andy Ruben: Oh my gosh. Great. And thank you for having me. It is awesome. Looking forward to it.

0:00:22.5 Cindy Moehring: Well, this is gonna be a fabulous conversation for all of you out there. As you know, this season is about all things ESG. And let me tell you a little bit about Andy and his company and then we'll jump right into the questions. Andy, who is the founder and CEO of a company called Trove, and that's the leading white label platform for brands that are now starting to realize that they need to control their secondary markets. And there's really cool brands. He partners with companies like Patagonia and Lululemon, and Eileen Fisher, and others, and more to come. So you'll for sure wanna check out that website. But let me tell you a little bit about Andy. I got to know Andy at Walmart where he was the company's first Chief Sustainability Officer. He also was the recipient of the Sam Walton Entrepreneur of the Year Award, which for those of you who don't know is Walmart's highest honor. He went on from that role and did a whole bunch of other things, including overseeing Walmart's global ecommerce strategy. And I think that may have been, Andy, where you got the bug to stay out where you are now in California, and do fun things like start this really cool company. But...

0:01:29.7 Cindy Moehring: Thank you again for being here today. Why don't you start by telling the audience a little bit about yourself and how you got to where you are, doing what it is you're doing today?

0:01:41.4 Andy Ruben: Sure. It's a big question. I never expected to be in... I never expected to be in business, frankly, as an engineer. Got a first job with Procter &ß Gamble, and fell in love with the people aspects of business. Spent years consulting where Walmart was a company I got to know, and got the opportunity to join Walmart, which I'm really a believer through all of this that... I think there's some people who believe that you know your whole career and it maps out just like your plan, you've got it on paper and you've got your bullet points; and other people, including myself, that believe that you take one step and then that step allows you to see around a corner you would have never imagined. And every step of my journey inside Walmart was like that. I started in corporate strategy and sustainability, unbeknownst to me, it became a topic. And I had the right place and timing to get to be involved in that, and then private brands and then e-commerce. And then left to start what's now Trove. And the experience along the way is everything from what I'm able to do now. That's all... I see it as very connected.

0:02:51.4 Cindy Moehring: Yeah, and you've kind of woven those pieces together, and I think it's just really valuable for the audience to hear that, because not all careers are linear. In fact, I would say very few are. A lot of them are back and forth and, to your point, you take one step and it leads you here, and you focus more on competencies that you're building along the way, and then you find yourself in positions doing jobs or starting companies like Trove that you never could have imagined when you got out of school, right? So that's...

0:03:14.4 Andy Ruben: Absolutely.

0:03:15.7 Cindy Moehring: That's really cool. So before we jump in and talk about Trove, let's just talk about the topic, like ESG. It seems like environmental and social and governance-related issues for corporations have taken a real kind of center stage seed, and you mentioned in your intro that, you know, sustainability was part of your job at Walmart, but you didn't realize it was gonna kind of become a thing at Walmart back in the day, in the early 2000s. And now it seems like it is front and center for all companies. Do you think it's here to stay front and center, and if so what do you think was the tipping point, what has caused it to take this position of prominence that it has today?

0:03:53.3 Andy Ruben: It's front and center because it's front and center for society. Business is always in the context of that society, and there are challenges that we as... There are challenges that people on the planet are increasingly facing. And one of the places that we look for answers, we look to companies. And so companies, if they are to stay relevant and continue to add the value that they can add to all of us, are going to be figuring this out. It is in the forefront right now because it is becoming more obvious that these things need to be dealt with.

0:04:35.7 Cindy Moehring: Yeah.

0:04:36.2 Andy Ruben: Yeah, I don't... There have been moments before where it's been more prominent and less prominent. I think it had a moment in the '90s that it was... There was... Back to the Walmart days, there was a committee that Mr. Sam formed with Hillary Clinton on the board and others, that when I had the right timing of being in sustainability in 2004 that a lot of suppliers reminded me of, even sent me some early notes from those time periods, and then it went into the background and then came back up. And so I think that there is...

0:05:09.9 Andy Ruben: It can ebb and flow, but ultimately I've seen it as a much broader construct, that if you are really thinking about the big picture you're thinking about these topics. It doesn't mean you can always figure out a... It doesn't mean you can always execute on everything right now, it often then requires coming back to where you are now, and figuring out the way to get from there back to here.

0:05:31.7 Cindy Moehring: Yeah, yeah. Do you think there was a tipping point that caused it to rise in prominence again right now?

0:05:38.1 Andy Ruben: There are a few tipping points. The BlackRock letter that Larry Fink said... And Larry Fink who is the CEO of BlackRock, which is a massive financial institution, sent a letter that I believe was a shot around the world, it was one of many, but the letter basically was realizing that business is from a risk perspective; that we're not looking at ESG, we're taking on undue risk on behalf of shareholders. And what was so interesting about that was the frame. He was not talking about polar bears in the Arctic or maple syrup farmers, he was talking about businesses and entity, and the job of a board of directors. And so there are other things that have followed. What just happened with Engine 1 and the Exxon board followed the same pattern.

0:06:28.7 Cindy Moehring: Yep.

0:06:31.7 Andy Ruben: So there are many of these, but I think that the shift has occurred from this being a nice-to-have to in the context of what a board of directors oversees, which is really the, "What is the plan, who is the management and what is the appropriate growth and level of risk professional management take on," have realized that this is now part of that discussion, because it is a risk that corporate entities are taking on beknownst to them or not.

0:06:58.9 Cindy Moehring: Yeah. Yeah, yeah. So it is a risk, and if they don't manage it then it will end up managing them.

0:07:06.8 Andy Ruben: Absolutely. And if the Exxon... Engine 1 and Exxon I thought was fascinating, because the shareholder resolution was not about the need for something. It was about the oversight of, Was management doing their job on behalf of the company and the shareholders? A very different framing than 10 years ago about the things that we need to be doing because they're good for everybody.

0:07:32.1 Cindy Moehring: Yeah, exactly, and I think that's really the key to this ESG movement, if you will. CSR, back in the day, if it was... Sometimes some companies called it that, or even sustainability, it was what you just said, doing some good things, which was great, but now ESG is talking about core aspects of your business, and how is what your core business plan, how is that also being kind to the environment, how is it taking into account all of the social issues and what are you doing from a governance perspective. So it's kind of baked in, as opposed to, Here's our business and here's what we do on the side. Right?

0:08:10.8 Andy Ruben: If it's on the side, it is always going to be... It's always gonna be sidelined, it's always gonna play second to the main priority. And the challenge with that is that business is such an incredible force in the world, one of the most incredible that capitalism in general, absolutely incredible. And if we really care about the future of society and what we've gotta get done right now, we better use everything that business is capable of.

0:08:38.1 Cindy Moehring: Yeah.

0:08:38.8 Andy Ruben: So why would we ever wanna neuter what a business is good at and not bring to full bear what business can really do. Which means there's gonna be a role for business, there's a role for society, and there's a role for government.

0:08:50.9 Cindy Moehring: That's right.

0:08:52.0 Andy Ruben: And business should think about how to be better business. And business, to be a better business is where the opportunity exists.

0:08:56.0 Cindy Moehring: Yeah.

0:09:00.7 Andy Ruben: This is getting into the heart of the podcast, I believe.

0:09:03.3 Cindy Moehring: Yeah. Yes, that brings us right to what you're doing now, which is Trove, business being a better business. So you have a lot of things to be really proud of right now with this company. I want you to tell us a little bit about the journey. But you've just raised a bunch of money in a Series D funding, and 77.5 million, I believe. And I think overall you've raised like $122.5 million, so you are really blowing and going and doing some great stuff to make business better. But before we go too far, tell everybody a little bit about Trove, and how long you've been at it. Has it been like nine years or something like that?

0:09:37.5 Andy Ruben: Yeah, so nine years ago, I realized that commerce or retail today was very focused on new items. But what we all focused on was not the new graphic calculator, it was a graphic calculator for my son or daughter in trigonometry, 'cause it's a graphic calculator. Whether or not that was a new calculator was kind of ancillary as long as it was the right calculator and it worked. And so for retail and brands really to serve customers, to be more customer-centric, this would just make sense; we're gonna light up and utilize all these hundreds of millions of items that are in our closets. In fact, our closets would become the world's biggest and under-utilized warehouse ever. They're there, these items have already been made. And so I realized that years ago, left to start what was called Yerdle at the time, which was a peer-to-peer marketplace, to address this and serve this need, to make use of the things all around us. Save money, save resources, improve people's lives.

0:10:41.5 Andy Ruben: I learned in that experience that it was bigger than I thought, more valuable than I thought, and I also realized that there was way too much friction to really change the way we do things. And that the right way in was not a peer-to-peer marketplace, as it was originally conceived when it was called Yerdle, but this was gonna happen through brands, because brands have created the system that we're in now, we trust brands, we love brands, brands have stores, like the Patagonia store, that make it easy for me to walk in with my jacket, brands have so much going for them. And some brands, the brands that produce incredibly high quality products, would get more longevity out of their products in a world where we kept these items in use.

0:11:29.2 Andy Ruben: In fact, there was just a report from Business of Fashion that said that only 20% of the value was being garnered in the first time an item was sold. So the first time Lululemon sells a pair of yoga pants, that's 20% of the value of the item that they've spent eight to 10 years with material research and product to invent and produce. And then the next 80% either sits idle or is captured by The RealReal. Why wouldn't Lululemon, who's done all the work to produce that item, get the next 80%? Why would it settle in my closet? So if by focusing on the best brands, the best brands could actually gain market share by doing this, and why wouldn't they? Because it's hard. So we pivoted the business five years ago to support brands who see this opportunity through a platform that essentially does all of the technology backbone and all the logistics that enables them to make the full use of the items they produce. And therefore as those brands start to do this, my view and change in the world is that we just all expect it.

0:12:36.7 Andy Ruben: So I look forward to the moment, gosh, 20 years from now, and someone's gonna say, "You worked on what? Of course when I'm done with the Patagonia, I bring it back to the store. What did you used to do with it?" And I will sadly admit that what I used to do with it is just have it sit old and dirty in my closet. Nothing. And they'll go, "Why would you do that?" And I'll say, "'Cause we didn't start... I don't know, we just bought things, we didn't think about the true value they can have when we're no longer using them." And so that's how I see our role and the opportunity to really support brands as the future winner of this space.

0:13:11.4 Cindy Moehring: So what you just described is the word that folks use for that now, kind of the circular retail economy. In other words, it isn't just used once, it's used, how many times... What if somebody takes it back to Patagonia now, and now they're done using it for the second or third time, how many times will they keep taking it back?

0:13:30.7 Andy Ruben: Why would you only... If Patagonia, why would you only sell an item once when you can sell it seven times? Nine is better than seven. Twelve is better than nine. And the idea, like when we think about how we view retail, final margin, why? Like initial margin, got it. Why not sell it three more times? So no, it's absolutely right, and it's right for not just the items that are well produced but the items that have demand in the after market. So when we talk... When I talk to any college student about Lululemon, I'm immediately I've lost the attention because everyone wants to know where they can go find a pair of Lululemon yoga pants for half the price. That's awesome.

0:14:15.0 Cindy Moehring: Right, right, right, right, right. Okay then, Andy, I gotta ask you a question. So isn't one of the roadblocks that Trove will face is the stigma of resale?

0:14:29.8 Andy Ruben: Not... No.

0:14:30.7 Cindy Moehring: Are consumers really wanting to go buy used goods?

0:14:34.4 Andy Ruben: Yes. And it's one of the things that... It's very generational. That would be like, what I would challenge that thought is, there would have been a moment, probably 10 years ago, for sure 15, but I got 10... If there'd have been a moment 10 years ago that I would have told you you would have willfully pulled out your phone and stepped into a stranger's car to get to where you're going, and you would have said, What? No, I would never do that.

0:14:56.7 Cindy Moehring: Right.

0:14:56.9 Andy Ruben: And then, by the way, you're gonna show up at somebody else's apartment and you're gonna stay there like it's a hotel.


0:15:03.6 Andy Ruben: Right? And you'd say, What? That is insane. And of course, this is... We think these things are set in stone, and they are not whatsoever. What is set... What is, I don't wanna say it's set in stone, but what is consistent is that it's not personal for us as customers, we want better items, we wanna like them more, we love new stuff, we wanna save money, we want it to be easy. Where it comes from, if today it comes from my phone and yesterday it came from a store, and before it came from someone on the Silk Road, it's the same equation. And what we want is we want more value for what we're doing, and better experience, and we want it to be easy.

0:15:47.8 Cindy Moehring: Yeah, and so you think it won't matter. That's interesting.

0:15:53.0 Andy Ruben: Absolutely. And with younger customers, and what we tend to see from the brands we work with, the customers who buy used tend to be on average 15 to 20 years younger, in the core demographic of the brands.

0:16:05.6 Cindy Moehring: Really?

0:16:06.1 Andy Ruben: So, Arc'teryx is one of the brands we work with. Super young customer who wants... If any of the listeners here have worn Arc'teryx, it's just... It's beautiful. Their stuff's beautiful. But it's expensive, because it's really well-made. And if you want Arc'teryx you can save up for a few years and/or you could find used Arc'teryx that used to be very difficult, when you can buy it from Arc'teryx, game on. And I look outside, both of the cars that we own, they're pre-certified. They are great and we got them from the dealer that gave me the same great coffee and donuts. They knew everything about the car.

0:16:43.8 Cindy Moehring: Yeah, yeah. How interesting. Okay, but you mentioned generational, so let me ask you another question about that and the business model, because I love the whole idea, but another potential road block. So let's talk about the next one. Generational, they're younger, they like this fashion forward stuff, they're all about the latest trends, and if you're doing resale of clothing items, isn't that kind of just the opposite of fashion forward? How do you capture the younger generation who wants fashion forward when you're reselling items that have already been out there, or were fashion forward five years ago?

0:17:21.5 Andy Ruben: There is a relatively small group of people who is, "I will only wear the ready-to-wear designer from this season, and I wouldn't be caught in the one from last year." The majority of us, and I'm in this group, really appreciate... It turns out I love Tom Ford. He's an incredible designer. And when I get to experience what a Tom Ford button-down shirt is to wear, I don't know why I ever go back to Banana Republic or J Crew ever again. And so, what most of us appreciate is better items, aspirational brands like a Patagonian, Arc'teryx, a Lululemon instead of a pair of Target yoga pants, we want things that we aspire to. And it's not every item, but there are pieces that we now have access to that we're excited about. And typically what we find is that while the customer who buys used tends to be 10 to 20 years younger, the customer who is handing back that piece is a core customer. So that customer is of the 40 to 60-year-old person, like myself, who's got four to five Patagonias but is wearing two. And I've accumulated them over the years. My kids never used to wear Patagonia, because they grow every year and Patagonia is expensive.

0:18:42.7 Cindy Moehring: Right, right.

0:18:44.5 Andy Ruben: But now they both do, and every year we walk back in, we... We have a store, which you can do it at any Patagonia right now, if it says Patagonia, you walk into a store, you hand back... We hand back our two kids' jackets, they hand us a gift card. So easy. We take the gift card, in store, online, we get them the next year's fit, the next year's size. They love it. They have a better jacket. They have a story... It's better than new. They've got a story about where the jacket came from. Patagonia stands behind it; it's clean, it's awesome. And the world does not need to produce a bunch of extra jackets so they can sit in my closet.

0:19:24.2 Cindy Moehring: Right, right.

0:19:24.3 Andy Ruben: That is... It's, again, 20 years from now it's gonna be amazing that we ever did the things... And we got here based on a post-World War II set of drivers that has created... It's brought a billion people out of extreme poverty. It's been incredible. But we are now moving into the next S-curve, where the value that we are creating has been and still does predominantly come from economies of scale of production and distribution. That is shifting from that to an S-curve that is about asset utilization and getting more out of the products we make.

0:20:02.0 Cindy Moehring: Yeah, yeah. I would agree with you on that, and I think that it's more about the story. You said that a few minutes ago, I mean the customers today really, consumers really wanna know what's the story, the story behind the recipe or the story behind the piece of clothing, so that's cool. Well, let's talk for a minute about Trove's own footprint, if you will. So the money that you've raised, I understand you're gonna be using it to expand operations, which is really exciting, I think, but with that will come a larger footprint for yourself. So how do you think about Trove's own footprint in the world, and how do you focus on minimizing that while at the same time trying to expand?

0:20:43.4 Andy Ruben: I realized this in the early days in sustainability at Walmart, because we did a... Walmart's got a pretty large footprint. And not even in terms of size, but just the things that in the world are kind of touched or seen. And when you look at the entire footprint, a lot of it comes back to ag, agriculture. It comes back to food, it comes back to textiles, so both ag. And if we can... On average, when we all make a choice to buy a used pair of yoga pants versus new, it's of footprint savings of between 40 and 60%. Depending on how much of that displaces a new item that would have been brought, it could be more. What the majority of us have been focused on previously is making items less bad. So we will take our pair of yoga pants and we will work on optimizing the cutting patterns, the sewing waste, the... So we work tirelessly to make an item 1-2% less bad. Every two to three years, we pat ourselves on the back. There is no amount of math to make 150 billion items we produce every year, for seven billion humans, less bad enough to deal with the challenge.

0:22:01.8 Andy Ruben: So one of the bullets, not the silver bullet, not the be-all-end-all answer, but one of the bullets is, Let's get three times the amount of use out of every item we've just made. So let's not just make a footprint or a supply chain 3-4% less bad, let's eliminate it 3X from what we just produced, let's eliminate three entire supply chain use cases by taking a Patagonia and having that item go through three more owners that it wouldn't have gone through, and replaced three new items. That's interesting to me.

0:22:32.1 Cindy Moehring: Yeah.

0:22:33.4 Andy Ruben: So we measure everything about our own footprint. We measure everything about the resource intensity of taking an item back, of the shipping, of the cleaning, all of it. It all pales in comparison to making that item in the first place.

0:22:49.1 Cindy Moehring: That's a really... That's a new kind of construct. A new way to think about it, right? So that's useful.

0:22:56.3 Andy Ruben: It's important. And sometimes I come across ESG strategies that I think can be misplaced. One of them that was from one of the big shipping companies that had a bit of a concern on their footprint, which is about how much they move items; it could be that moving items around is the best thing we could do for a smaller footprint, but their role was gonna be to take all of these items, move them from our closets, and get them to the next person. They no longer then, in that case, should be ashamed of moving things around, they should be proud of it.

0:23:30.7 Cindy Moehring: Yeah.

0:23:31.3 Andy Ruben: So I think we've gotta be careful, back to the broader business conversation, that we look at this system.

0:23:34.3 Cindy Moehring: Yeah. Right.

0:23:34.7 Andy Ruben: And we realize that shipping is not bad because it's shipping.

0:23:40.9 Cindy Moehring: Right, right. It depends on what is being shipped and for what purpose, and not just saying shipping is bad. Yeah. That's...

0:23:48.1 Andy Ruben: That's exactly right.

0:23:49.2 Cindy Moehring: The way to look at it. Alright, a couple of other questions. There are so many different frameworks out there right now for measurement of ESG, and so are you dealing with sort of like when you were a Walmart, a retailer, you're going into the factories and there's all the different standards that the factories have to comply with, are you faced with that with all of your customers and the different ESG rating metrics and measures that they're all trying to attain? Or are you starting to see some rationalization and thinning of the frameworks and...

0:24:27.5 Andy Ruben: We're definitely seeing more focus on it. Some of the investors that came into this latest funding round that you mentioned, we had more questions about our own footprint and our measurement of that footpreneur actions than I've ever had before.

0:24:42.1 Cindy Moehring: I bet.

0:24:42.2 Andy Ruben: And that was wildly encouraging. So we are seeing some continuity. I think that the work in the UN has been helpful, but at the end of the day I think that it is also very difficult, if not impossible, and I'm not sure, but it's very difficult certainly for an outside organization to measure how good a company is with a statement like that, or how well a company is doing, looking at transactional or ad-hoc transactional metrics. Because it's very hard to not miss the forest through the trees of what's been measured. And that's a very difficult thing to do. Will the metrics to measure this one element of a business ever get good enough to really assess that? Maybe.

0:25:30.0 Andy Ruben: But in the end it's gotta be assessed more holistically. I like the metrics right now because they're creating focus. I don't like the metrics they think that they're actually gonna figure out the perfect metric so we can all drive that. Business has one metric right now which is actually creating value in the world. When business creates more value in the world, and value in the world if you wanna think about it right this minute involves a certain set of things, when you wanna think about it in the long-term sense of what it's gonna mean in a year... In two and three years, you'd better be looking at the longer term, bigger context. That's going to include ESG.

0:26:03.4 Andy Ruben: And if you hire the people who are good at doing that, they're gonna be the same people who are good at figuring out the near-term value as well. So every time that we communicate a dollar sign as Trove, with our partners, with customers, we also think about the jobs and the upward mobility, we also think about the CO2, we think about the waste, we're talking about the business and the way to measure the business. So when you're really thinking about that, those metrics go together, they often can't be parsed to understand what's going on.

0:26:38.8 Cindy Moehring: Yeah. Yeah, I would agree. It's certainly a very complex issue, I think, and if you don't really understand it the way you were just talking about, you can over-simplify it in a way that then it becomes meaningless, in terms of trying to really figure out, what are we really after here? And if you just look at the core measurements, like you were saying, as opposed to the bigger picture, you kinda do lose it. You know, you're in the trees and you miss seeing the whole forest and what you're after. So we'll have to see how that goes.

0:27:06.2 Andy Ruben: It's definitely a topic, and the very practical advice I would give, and I think this is how it probably needs to be viewed by many, is no one should take their eye off the longer picture where the value is really being created and make sure that these things are all connected. At the same time, it's important to continue to answer the questions in the surveys...

0:27:28.7 Cindy Moehring: Yeah.

0:27:28.8 Andy Ruben: As we make the survey questions better.

0:27:31.6 Cindy Moehring: Yeah, I would agree.

0:27:33.4 Andy Ruben: It is both.

0:27:33.8 Cindy Moehring: It is both. It is both. Well, Andy, this has been a great conversation. Thanks for answering a bunch of hard questions, and now I have a really easy one for you, but a really fun one, and I think it'll be instructive for the audience. For somebody who wants to just learn a little bit more about this whole topic of ESG or the circular retail economy or anything in that bucket, what would you recommend as a good book, or a good maybe podcast, or a good documentary? Do you have anything comes top of mind for you?

0:28:01.1 Andy Ruben: Still the book that... One of the questions that... I didn't know David Brower from the Sierra Club, but people close to me did know him. One of the questions he'd always ask is, What bit you? Which is like, what kind of sparked the curiosity that had you go down the rabbit hole? For me it was Paul Hawkins' book, Ecology of Commerce. And still to this day... That book was eye-opening for me. It was the start of the rabbit hole for me of, How could I not have been thinking about these things? And so that remains... What I would say is the curiosity, deeper into how things work, is regardless of the... Regardless if it's a factory, a supply chain, a product, a service, just keep going deeper into why things are the way they are and how to think about them in a broader context. And in every one of these... No matter how much better things have gotten, how good business is today, it's one 1000th of what it could be. And so that just inspires the openness and the creativity of... The opportunity is to figure out ways to make it better, and if you're really gonna figure out ways to add value and make it better, a lens toward broader sustainability is a really important lens to think big enough.

0:29:22.5 Cindy Moehring: Yeah. I would agree. Well, that's a great recommendation. Thank you again for your time. This has been an incredible episode, and it's just really great to see you again, so thanks so much, Andy, I really appreciate it.

0:29:33.8 Andy Ruben: Oh my gosh, thank you. Totally fun.

0:29:38.2 Cindy Moehring: It's been great. Okay, talk to you later. Bye bye.

0:29:38.8 Andy Ruben: Bye bye.

Matt WallerCindy Moehring is the founder and executive chair of the Business Integrity Leadership Initiative at the Sam M. Walton College of Business at the University of Arkansas. She recently retired from Walmart after 20 years, where she served as senior vice president, Global Chief Ethics Officer, and senior vice president, U.S. Chief Ethics and Compliance Officer.

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