In this episode, host Cindy Moehring sits down with Global Vice President of Ethics and Compliance at Anheuser-Busch InBev, Matt Galvin. They discuss a variety of topics such as how COVID-19 has affected business ethics and how businesses operate today, how Matt’s role as vice-chair of the anti-corruption committee of the Organisation for Economic Co-operation and Development (OECD) has informed his views of future risk management practices, and the up and coming importance of data analytics in business compliance.
Podcast:
Episode Transcript:
0:00:00.8 Cindy Moehring: Alright. I have with me today, Matt Galvin, who is the Global Vice President for Ethics and Compliance at AB InBev. Welcome, Matt!
0:00:08.9 Matt Galvin: Hi, Cindy. Welcome. Thank you.
0:00:11.5 Cindy Moehring: Glad to have you here today. And for those of you who don't know, AB InBev is the largest brewer in the world. It's co-headquartered in Belgium and in New York. For many of us here in the US, we're most familiar with the A-B part of AB InBev, which is Anheuser-Busch. That's how I always knew it. I'm from Missouri and grew up there, so Anheuser-Busch is the part of the name that I know the best. AB InBev now, though, has approximately 170,000 employees in over 80 countries. It's a Fortune 200 company with revenue in 2019 of over $52 Billion. So in addition to serving as AB InBev's Global VP for Ethics and Compliance, Matt's also the Vice Chair of the Anti-Corruption Committee for the OECD, which is the Organization for Economic Cooperation and Development. And in his free time, somehow he finds free time, [chuckle] he's also the adjunct professor at Fordham Law School, teaching a law course there. Now, before joining AB InBev, Matt was in private practice with several national and international global law firms. And one of the most cool things about Matt is that he is also an alum from Georgetown University Law Center. Go Hoyas! We share that in common. Thanks for joining us today, Matt. It's a pleasure to have you here.
0:01:30.3 Matt Galvin: No, thank you so much Cindy.
0:01:32.7 Cindy Moehring: Well, let's dive in with you really talking about how the practice of governance and risk management, and ethics and compliance has changed over time. We're looking at that topic from a couple of different angles and interested in your views. You've been in both private practice for many years now, and also in-house. What are the most striking changes that you've seen in how the practice of these risk management functions have changed over time?
0:02:05.5 Matt Galvin: Sure. In talking about change and compliance this year, it's impossible not to talk about the change caused by the global pandemic and how compliance itself... All compliance officers had to pivot and re-prioritize just like everyone else in the businesses around the world, on the fly, with what we needed to manage. A lot of us became experts in safety. Then we became experts in contact tracing, in immunology, in epidemiology, and how do you manage a safe workplace? Once you get beyond business continuity, you realize that the pandemic has also radically changed how we're interacting with our communities and with the other stakeholders, the governments, and other organizations, and our supply chain and their communities. As much as we're hyper-international in terms of a beer company, beer's very local. Our supply chain is made of things that are heavy: Water, barley, hops. Our brands tend to have very... As much as Budweiser is an international brand, which might sound strange to someone from Missouri, but more people drink Budweiser in China now than in the US.
0:03:25.3 Cindy Moehring: Wow! I didn't know that factoid, that's interesting.
0:03:29.9 Matt Galvin: I have all sorts of facts about beer.
[laughter]
0:03:31.9 Matt Galvin: We could do a whole separate podcast on beer, if you want.
0:03:34.7 Cindy Moehring: That'd be fun! [laughter]
0:03:35.9 Matt Galvin: Yeah, happy hour. But we're super local in the nature of our business and the nature of our supply chains. And so with our communities at risk, we had all these projects of creating hand sanitizer from spent alcohol for non-alcohol beer. And used recycled bottles to create plastic visors for medical professionals in Latin America. And a new one, our Brazilian subsidiary, AmBev, is part of eight different companies doing... Scaling the vaccine that AstraZeneca and Oxford are doing because we're good at fermentation at scale.
0:04:15.9 Matt Galvin: And so we have expertise in how to take something like that, and even, it sounds strange, but we're actually involved in the scaling of vaccines in Brazil. Now, from a compliance professional, that's awesome, and I wanna be a business enabler for that. You have very different ways that you're engaging with the government and you have to pivot very quickly to allow for those sorts of new government interactions to proceed in the right way. If you put your FCPA or Foreign Corrupt Practices head-on, you have certain markets where PPE is wildly inflationary. The bidding war goes up as much as we saw it in the States, that's amplified across emerging markets in Latin America and Africa. And then you have governments designating what PPE is needed. Well, then you have this twin FCPA cocktail of a highly inflationary environment that has to move quickly with government involvement in terms of what you can and cannot do.
0:05:10.9 Matt Galvin: And so staying on top of those risks, communicating with the teams, and enabling the business to pivot very quickly has been a big area where compliance has changed this year. When I look at how compliance has changed over the last five, or six or 10 years... I remember my practice, when I was in private practice, is mostly in East Asia. I lived in China for seven years. I remember doing compliance trainings in China, 12, 13 years ago. And it was really, really hard to get people's attention. It was entirely about US law, so right away you're talking about something that's from Mars. And the murkiness and the greyness of some business practices, and how they translate in the FCPA can lead... It's not necessarily great fodder for a clear training of introduction to anything because it comes very nuanced and very difficult, very quickly.
0:06:05.5 Matt Galvin: But then when I was practicing in Hong Kong between 2011 and 2014, that all changed. And the attitude and the government pivot towards corruption completely changed. And the people, the residents, the masses, it was very easy, and compliance trainings were very easy to give in China in 2014. Because it was very focused and very top in mind because of the domestic government focus on corruption. And we've seen a similar change in the last five years in Brazil with Lava Jato and the focus there. And then other markets around the world, you see just a complete change with how people perceive this. Guatemala, with a special prosecutor, parts of South East Asia with other UN initiatives, and you see an amazing change. And so that's really changed how the message can resonate and how we communicate and how we can operate within a global business.
0:06:55.6 Cindy Moehring: So if you've seen the frontline managers really pick up and own this message more than they did today... I think back when you were talking about when you were doing the training before, it sometimes felt like compliance and ethics was owned, if you will, by the Compliance and Ethics Department where we are a business enabler in many companies and it should be owned by the frontline managers. Have you seen any change in attitude there with the uptick and enforcement of it around the world?
0:07:23.8 Matt Galvin: Yeah. I'm sure you've had experience where it's simultaneously like, you can have programs where you can say everyone's responsible for compliance and then you risk that no one is. But you also have on the other end of the spectrum, if every corrupt action is the responsibility of compliance, well then typically, we're not the ones running around acting badly.
0:07:42.1 Cindy Moehring: Right.
0:07:42.7 Matt Galvin: And so having the right balance of local commitment and embedding compliance processes into incentive packages and vetting compliance processes into how you architecture your IT, your solutions, there's so much partnership that's required. If you don't have senior leadership on it, you won't succeed. And you can have the best policies in the world, but there's another... I think there's a Chinese expression, "The mountain is high and the Emperor is far away." And so this idea that you can have the best thing, but if you're not integrated with the business and they don't feel your presence either through leadership or through some other means, it's not gonna matter.
0:08:25.4 Cindy Moehring: So do you think that's changed over the years? That people, business managers, have engaged more?
0:08:32.7 Matt Galvin: I think having more polls of anti-corruption prosecution has made it a lot easier. You have Brazil and China, which are massive economies and hugely important to our business, changing their focus on China and changing their focus on corruption. Particularly on supply side, multi-national part of corruption has really changed how local managers view it.
0:09:01.7 Cindy Moehring: Yeah. And there's also cross-government sharing of information in these global cases now that deal with corruption, whereas I don't think that was so much the case before. So some of the government agencies will share that information and it becomes truly a global issue.
0:09:21.8 Matt Galvin: Yeah, totally. Right. You can go back to... In the Siemens's case, I think there was quiet exchange that led to some domestic Chinese prosecution about 12-13 years ago, but it was super opaque and not that clear how that all went down. And then you had, for a while, and I think you still have this in some markets, just a total fear of attack on prosecutions, a fear of... And this UPA case then suddenly the local government wants to jump in, and then you have 10 different regulators calling. And I think there has been a lot that are cold communication, which in a lot of ways... In some ways, it's increased the risk profile, but in a lot of ways, it's made it easier to manage because it means you're taming one big lion instead of hurting 15 small cats.
0:10:10.9 Cindy Moehring: Staying on the global point here for a minute, you've just picked up a new role with the OECD as the Vice-Chair of the anti-corruption committee. Share with us a little bit about that role, what you do in that role, and how that's informed your views about the future for the practice of risk management.
0:10:31.0 Matt Galvin: It's so new, but it's been a really great experience, and just seeing tremendous dedication of the OECD staff and tremendous dedication across the business at the OECD Committee. And what it is, is a group of business leaders that have an advisory position with the OECD and its policy creation arm. And so you simultaneously get the opportunity to see how the OECD is working with governments around the world in setting policy agenda and exchanging best practices, which I think is incredibly valuable work, but then they also realise that business needs to have a voice in the creation of that. And so that's the role of the business committee, and my committee is specifically focused on anti-corruption. And one key regulatory change, if I had either a crystal ball or a magic wand, I'm not sure, some combination of the two, I would like to see a corporate compliance defense so that if you have an adequate compliance program, have that be a complete affirmative defense to a charge against a corporation for corruption.
0:11:44.8 Matt Galvin: And part of what my mission to mandate with the OECD is A, to move things towards that. And B, is since we do a lot with technology and a lot with the analytics of AB InBev, and moving, and how you can use that analytics to actually measure effectiveness of compliance, that, to me, is tied very closely to that goal of adequate corporate compliance. Because you can actually measure compliance adequacy or measure risk through insights in the data. Well, then you actually have a better metric than is currently available at measuring the effectiveness of compliance program. And so if you do that well then, how could you not have a regulatory environment that both incentivizes that and recognizes a company that has it when they're doing it?
0:12:37.9 Cindy Moehring: Yeah. That's a really good point. Well, I think you have a great platform from which to push for that, with the OECD, given the work that you've been doing at AB InBev in that space. So let's move there and talk about data analytics and the BrewRIGHT data analytics platform that y'all have set up there. So effective data analytics, I think, we all know is the future generally, but it's also the future for ethics and compliance, machine learning and artificial intelligence and using that in our programs. But interestingly, there was a study from 2019 that said only about 13% of the ethics and compliance programs that big companies were currently even using AI to fight fraud. You at AB InBev is a company that's... I would say, at the tip of that spear of using artificial intelligence and data analytics. And it's interesting because you're not a tech company and I think people would expect a tech company to have that mantle. So I find that even all the more interesting. So could you explain to us a little bit about the analytics platform, I think it's called BrewRIGHT, and how it works?
0:13:44.9 Matt Galvin: Sure. So we're at year four plus now of our journey with that analytics and our journey with the BrewRIGHT platform. And a good way to think about it, it's like a system of roughly 16 different compliance apps that each compliance app takes your commercial data, and certain compliance data and then helps compliance officers solve a compliance issue. And then the workflow with the compliance officer and using the app, it also creates a data set that we then use to inform the underlying models. So it's a system of both compliance processes and compliance risk indicators that then learns as compliance officers use the system, which is pretty cool in itself. But then what it also does is allow for dynamic insights in the risk across different business lines within the company. And so different apps can interrelate and inform each other as each one gets smarter than some of the other... Cogs in the wheel get smarter. And then everything gets more efficient, but then you can also see where certain risk indicators lie and where you should allocate resources.
0:14:57.7 Matt Galvin: Let me give you an example. So starting back at the compliance app. Well, what's the problem compliance officers have? Well, one would be okaying your supply chain or your value chain. Which third parties are you worried about interacting with the government? And that's a very standard NCPA question. So who should I diligence? Now, we have a rule and we've always had a rule, or at least the last 10 years or so, that if you're interacting with the government or you're with a third party agent, well, they have to go under due diligence, they have to go through a compliance process. So what we did was go into our ERP systems or our accounts payable systems, or what procurement uses to manage their parties, and we took a bunch of data and indicators from that and started to build models of what does it look like when we pay a third party vendor or when we set up an invoicing system or PRPO for a third party vendor.
0:15:50.4 Matt Galvin: And over time, since we've cataloged in tens of thousands of these vendors, the model, what we started with was a few rules that predicted about six or 7% accuracy in which was not great, and now predicts basis over 90% accuracy, which third parties are interacting with the government. So that helps compliance officers very quickly go through and be like, "Check, check, check. And this is what I need to do."
0:16:14.7 Matt Galvin: And then what happens? Well, then you start cataloguing your vendors and you assign risk profiles to certain vendors compliance. And then you look at the payments against your risk profile. And that manifests in two ways. One is to check your diligence. So if, suppose you diligence a vendor to do legal services in Mexico for a litigation, but then suddenly they got a bullet payment for advisory services in dollars for a customs issue in Cancun. That's not what you diligence them for. And so you have this ongoing flying that can pop up if the way you're interacting with the vendors is not the way compliance approved you to. And then even a more ambitious would be, "Okay, what payment was what vendors would actually be indicative of fraud and corruption?" And so what are the problems based upon historical investigations, based upon our proactive monitoring to both you'll identify what specific transactions, or what specific vendors should warrant additional review, all with a goal. I have to say we fell short of our initial goal that we set five years ago that we'd be able to predict and prevent fraud and corruption before it occurred. I don't think there's the ability to do that yet. We're still just a very effective audit mechanism.
0:17:32.0 Cindy Moehring: I see.
0:17:32.2 Matt Galvin: But I think as it evolves and as it gets... As it improves, I still see it's within reach to intercept payments in that processing system, as you're going through your business processing you kind of... A business process of consummating a payment that you'd be able to intercept things before they happen. And that's the goal. That's three or four of the dashboards and how they interact. And then they build a view of the risk profile of a business unit. Yeah.
0:18:00.7 Cindy Moehring: Yeah. So the other thing that struck me as effective with the BrewRIGHT analytics platform from what I've read about it is that other frontline areas of the company have access to it and use it as well. So it's very transparent in it's use, and can be used by sales folks, and the folks in finance and as well as the folks from compliance to all look at the data together. How does that play out?
0:18:37.0 Matt Galvin: One of the advantages we had... I think in an early version of BrewRIGHT, was to take and create this app based structure of 16 different apps. Because the first version of it, before we had started actually doing it, before we went to scale, we did a test program about five years ago. And we looked at systems data from Brazil and India. And you write a single dashboard that you could pretty much look at everything, and it was super cool and you could go in and out, but it was so complicated. It was like the cockpit of an F-16 and it's like, "Okay, this is great," but it's me and maybe the head of audit will ever really ever use it. What the app approach allowed us to do, was have certain workflows that we keep to a smaller group within the high priests or priestess of compliance. And then portfolios, like searching for duplicate payments, which is normally the providence of control or audit, and we could release those to a broader use of different people in the business.
0:19:37.4 Cindy Moehring: I see.
0:19:38.3 Matt Galvin: So right away you have different workflows that allow for, say when our corporate credit card spend, we have certain workflows that get triggered, that go to procurement or the people that manage just your rules around expenses. And other ones that would go to compliance because they're indicative of either alcohol beverage laws or corruption concerns and risk. And so this creates separate workflows. But the other piece about it, one thing I have decided a few years ago when I was elevated to the colonel role, was really one of the kind of both opportunities and missions of a compliance officer should be to drive transparency by bringing that together and allowing breaking down silos and allowing different functions to see what each other was doing, at least with their money. It was a great... Was a much better way to manage risk, than just processing people to death. And the more transparency using drive to what they're doing, the better people are gonna manage their own risk and help manage each other's risks. And you enable a lot of things to both operate more effectively and manage the risk more holistically.
0:20:46.5 Cindy Moehring: And so how is that playing out then in AB InBev? Because I really... I think that's super important, is to operationalize it and let the frontline managers essentially understand it better so they can start controlling it on their own. Have you seen some real benefits in that regard?
0:21:04.5 Matt Galvin: Totally. And just the speed and access to information is very empowering. I remember a while back where we were integrating our businesses in Africa, there was a question about our how procurement processes run. And for me procurement does as much, if not more, of third-party risk management than compliance ever would, because just the vast majority of agents are going through them rather than us. And so you can quickly see, "Okay, we have questions in the data about, are the procurement processes being followed perfectly in a certain country?" And the head of procurement would be like, "Oh, it's fine. You can see. All my people tell me it's perfect," but then you have the data and you can quickly say, "No, I see these one-off payments being made here and these going here," and you can quickly just cut through a lot of the fact collecting that can lead you to discussion, and you can have one meeting instead of seven.
0:22:00.2 Cindy Moehring: And one version of the truth it sounds like, because it's all in one platform that's transparent, that everyone can see.
0:22:06.5 Matt Galvin: Absolutely, exactly. And that allows different business functions to see, quickly interact, identify a problem and address it without having to get lost in what might not come through in a normal fact-finding process, or traditional fact finding process.
0:22:22.8 Cindy Moehring: That's really, really valuable. So what do you think's the next step for BrewRIGHT? What's the future? What are you working on next?
0:22:29.9 Matt Galvin: Well, one of the difficulties in building, creating AI, or supervised learning models for something like corruption is... Well, we're by no means a perfect company. It's not like we have so many instances of issues that I can really have a dataset that will train really good models. If you look at your corporate credit, your credit card, your MasterCard or Visa, they have really good algorithms that look for fraud against credit card companies. The reason why they have it, it's something that they have 200 instances of fraud per second. And that can build... Once you start identifying that, the dataset you get from that is extremely powerful, which is why they've over 99% accuracy when someone tries to rip off the credit card company.
0:23:18.4 Matt Galvin: To build that with a company, ours, even with our massive scale, it takes a long time to build datasets and label them correctly to really build super effective models. And so the better way to do it would be work as part of the consortium. That if you start pulling insights in the transaction of patterns across a multiplicity of companies, well, then you can start to hit a scale that will allow your models to get better exponentially faster, particularly if during this providing feedback into performance, and then you train really effectively what is not only a risk transaction, but what is always safe, what's always a safe transaction. Vendor profile would always be safe.
0:24:04.1 Matt Galvin: These, we have massive datasets for. And you can really build together through a consortium, models that I think would be incredibly useful to the... Not just the compliance community, but the business community as a whole. And so I think the next step in the journey, and this is something our CEO talked about at Davos in January, is taking models based off BrewRIGHT and unleashing them as part of the network or a consortium where multiple companies can share insights. And one of the neat innovations in the architecture... We're halfway from ideation to implementation, but it's an idea of putting that on a distributive platform so that these insights can be shared without sharing any underlying data, and creating a secure exchange of information through patterns in a federated way with you across the whole network.
0:25:03.4 Cindy Moehring: Very interesting. So between ideation and implementation, are you talking with any other companies about that yet?
0:25:11.9 Matt Galvin: Oh, very many.
0:25:13.3 Cindy Moehring: Yeah.
0:25:14.4 Matt Galvin: There was a lot of interest both...
0:25:15.4 Cindy Moehring: A lot of interest.
0:25:15.6 Matt Galvin: In terms of the tech-..., in terms of building in the companies where to start, because the thing about... I don't advise anyone to try to recreate a BrewRIGHT in their spare time. It was an arduous and expensive journey, but one that had a lot of support, and a lot of victories as well as a lot of setbacks along the way. What I do suggest compliance officers do, is start hiring data scientists and data engineers to help them get insights. And then what's gonna happen is... What a consortium is gonna do, and this is important I think with any... The success of any technology. It's gonna make it a lot cheaper to do this, because the cost of doing a BrewRIGHT, a lot of it is figuring out how to normalize data and get data that... In a form that you can run algorithms on. A little bit is on getting the algos, but you can get cheap algos for free off the internet if you were to google, "What's a pattern for fraud?" The problem is there's no connective. Because the true cost of it is when you're using algorithms that aren't that effective, you get a lot of false positives, and the time and energy you take reviewing transactions is either expensive in terms of human hours or ---.
0:26:27.3 Matt Galvin: And so by skipping through... If you start with models that are much more predictive, and you already know what that is in the pilot, you're gonna leapfrog several steps and cost concerns that you would have if you tried to do it on your own. And so part of the goal of the network is just to make this really cheap and really accessible business community into other stakeholders so that you can move forward very quickly.
0:26:52.6 Cindy Moehring: One last question on BrewRIGHT. Is it used for any other aspects besides fraud and finding patterns in fraud?
0:27:02.0 Matt Galvin: Yeah. There's 16 different apps that do so many different things. But with some of our business units we even have arrangements that when we recover money, we split the proceeds with the business unit and the feedback and with BrewRIGHT. So that's looking for duplicate payments or just accounting issues. We track any patterns within our case management system for investigations, so that if you had high incidents of theft in a certain area, you can pick up that that's an issue. We also will evaluate how cases are investigated and managed. What's the average length of time that certain cases take, and then what's the substantiation rate of certain investigation units or certain investigators? So that you can evaluate the performance of the compliance team itself. We'd look for indicators of their investigations. Are you treating more senior people within your investigations portfolio softer than you're treating more junior people, or is part of your business just soft on crime?
0:28:02.1 Matt Galvin: And so we have a lot of metrics that we use to evaluate the performance of our compliance teams itself. And there's more, we have a really cool corporate credit card analytics tool that is... I think we recovered something like 400,000 I think, this year in a single business unit...
0:28:22.0 Cindy Moehring: Wow. Wow.
0:28:23.5 Matt Galvin: Of good use. And so there's all sorts of stuff that different aspects of the program is... That we look to make our ROI, particularly this year, where...
0:28:33.8 Cindy Moehring: Yeah. Hard year.
0:28:35.0 Matt Galvin: It's not a great year. Yeah, it's a hard year, so anything we can do to help the business. Four hundred thousand is not a big number for my company, but it's a bigger number that most compliance programs have for a single business unit.
0:28:47.9 Cindy Moehring: Yeah. One last question for you before we'll turn to a fun question at the very end to wrap it up. You were just talking there about helping the business. My question to you is, what can universities and business schools in particular do to help future business leaders, those folks that you advise at AB InBev, be prepared to manage this evolving world of risk management and governance, and ethics and compliance better as a front line manager? If there were three things that you thought universities could do to help in that regard, what would it be?
0:29:30.8 Matt Galvin: I have a great fortune. I get to do work, a lot of work with different parts of academia, and now and then I come across folks focused on different parts of corporate ethics. And one thing whenever you talk to someone doing ethics, the first thing they always tell you invariably, is how few people are doing ethics and how few programs have an ethical component to them. And I think as you reflect on... If you do this long enough, and I'm sure you had this experience, you've seen so many people reach points in their careers, they just made either stupid decisions, or unethical decisions, or some sort of decisions, that I'm sure had they taken a time to reflect or either had the skills or tool set to reflect, they wouldn't have made, and they realized that the cost-benefit that they thought that were running, was way off.
0:30:19.9 Matt Galvin: That they total either the costs, either that they just didn't have certain types of... Enough third rails of what they wouldn't do in their calculus, that it made what should have been an easy decision, very difficult. And I think that's a big challenge. I think one thing I've benefited from... A lot of people ask me, 'cause I do so much in technology and law and compliance, that I must have some sort of technical background. My undergraduate degree was in creative writing and Chinese studies. But I think when I look back, having spent the most time in China, well I get very comfortable operating in an environment without always knowing exactly what was going on. And so I think that was a lesson and a humility that I... Whenever I'm deeply immersed in tech discussions, I've gotten comfortable in environments. And I don't always know exactly what's going on, but I'm not afraid to ask stupid questions. I'm not afraid to ask, "What does this mean? What is that?" And just build blocks that I understand and can articulate and explain things. I think the third is... I think consensus building and communication are two very under-appreciated corporate skills.
0:31:34.9 Cindy Moehring: Yes.
0:31:35.8 Matt Galvin: And the ability to bring people on, recognizing interested stakeholder groups and understanding how to communicate effectively across is so critical to doing something like building a legal analytics platform, because you have to talk to so many different functions. And finding ways to meet them halfway while you're trying to achieve the vision. So for better or for worse, I'm fairly flexible with how this evolves. It can drive my teams absolutely crazy as we pivot, but I think it's necessary to have that flexibility in order to get acceptance for a program like this.
0:32:13.4 Cindy Moehring: Yeah. No, I think you're right, and those are three really good points so thank you for sharing those with us. So one last fun question as we wrap up here in this COVID time that we're in. Have you read anything or have you watched anything of late that was kinda fun, but also interesting and had some sort of an ethical dilemma to it?
0:32:37.4 Matt Galvin: Yeah. I oscillate from super-complex data analytics and then my children's movies on a regular basis.
[laughter]
0:32:47.0 Matt Galvin: And then when I have a moment, Harari's recent book, the 21 Lessons for the 21st Century...
0:32:53.1 Cindy Moehring: Yes.
0:32:53.2 Matt Galvin: I think it's... One of the book chapters is talking about, we face so many problems that are truly global, yet our political systems are hyper-national and are they equipped to solve it? And he said getting focus in climate change is a great example. In many respects corruption is a great example. But as we look in the last few months, the question of a corporation's role within ethical and geopolitical challenges is really being revisited.
0:33:26.0 Cindy Moehring: It is.
0:33:26.5 Matt Galvin: Can a corporation sit on the sidelines of a difficult social debate? Can it truly be apolitical or can it truly not have to take a position on climate change? And these are questions that are driven, and correctly by part consumers, but also part by the management and the people themselves. Do you wanna be part of a company that isn't taking a position on these things, and what does that say? And is that the right goal? And I think traditionally, it was so accepted for corporations to stay out of the fray. But there's a different set of expectations now. How far that's gonna go and how long that's gonna last? And do you necessarily want your corporations to be political? Or fundamental questions that we're all struggling with.
0:34:15.9 Cindy Moehring: Yeah, I agree. Well, Matt, this has been fantastic. Thank you for taking the time out of your COVID day to have this conversation with us. It was incredibly interesting and inspiring to see how far one company has come with the use of its data analytics, and I love the consortium idea. I look forward to hearing more about that. So thank you very much.
0:34:41.7 Matt Galvin: Thanks, Cindy. No, it's one of my favorite parts about the compliance community, is how open and helpful we are, so I like to be a part of it.
0:34:47.8 Cindy Moehring: I agree. Alright. Bye.
0:34:50.6 Matt Galvin: Thank you.
