On November 17, 2016, Diane Nobles spoke in front of a packed room of students eager to hear her stories of a career in the area of business ethics and corporate compliance. As the 2016 speaker for the Leighton Lecture on Ethics and Leadership, Nobles gave a talk titled “Ethics, Leadership, and Stories from the Front.” Nobles got into corporate compliance initially not because it was where she wanted to be, but because it was a position that her company needed to establish. And she seemed the person for the job. Though initially reluctant, she accepted the challenge and went about setting up this new office of compliance at her company. She starting doing research, attending conferences, and speaking with new colleagues in what was a fairly small field at the time. As she did so, Nobles discovered that she really enjoyed the position and came to appreciate its importance within a corporate culture. She also learned that it was not an isolating position. “It wasn’t just me and my compliance department,” she said. “I had to know the business. I had to form very strong working relationships with audit, with finance, with human resources—with other partner functions that were going to help me deliver and reinforce the message that I was trying to send.” In an early experience in corporate compliance, Nobles was working at a company that negotiated with pharmaceutical companies on behalf of companies that were providing a self-funded insurance option. As part of that, committees decided which drugs go on the drug formulary to determine which are fully covered or have some cost associated with them. This committee included people who actually negotiated with the manufacturers. Nobles felt there was a conflict in that decisions could be made based on what drug selections provide the most benefit to the company versus those that are most appropriate to treating the disease. She felt these committees should be made up solely of clinicians with no vested interest in the final decision. It was not that the process was illegal—it wasn’t. It was that Nobles felt that it did not reflect well on the company and that it could be a problem in the future. She ended up meeting with the CEO, who agreed and changed the company’s policy. Just a few years later, many companies did indeed get in trouble because of similar actions. Nobles’ did not. “Without trust, my CEO would never have listened to me all those years ago about how we put drugs on that list,” Nobles said. “But he believed I was competent. He knew I had integrity. He knew I had the best interests of the company at heart. It was not about me, it was about the company, and ultimately the shareholders.” Nobles also discussed the recent problems facing Volkswagen and Wells Fargo—both stemming from a breakdown in an understanding of how a corporate culture should behave ethically. Nobles said, “I think sometimes making decisions based on short-term gain is where you are going to run into some ethical problems. You have to be able to look further out than a quarter or two quarters or a year down the road.” Nobles also shared a decision-making model that she developed after first getting into the area of corporate compliance. The model works on the acronym TRUST:

• Think about the situation.
• Recognize and analyze the motivations.
• Understand what the rules and regulations are.
• Satisfy the headline test.
• Take action.

The headline test, as Nobles described it, means that if you woke up in the morning and your decision was on the front page of the New York Times, how would you feel? “That’s a really quick, down and dirty way to see if you can get comfortable with whether you are in the right place,” she said. And when poor decisions are made, it’s not often a sign of poor corporate culture. “Most companies really do want to get it right,” said Nobles. “They’re not out there intentionally trying to do things unethically or illegally. . . . Some of them do some incredibly stupid things. But some of them are really just trying to work their way through what is ultimately a gray area.” For Nobles, a decision-making model like the one she presented one can help employees and companies determine how they should proceed in an ethical manner. The decisions may not be easy. As Nobles explained, “The gray area is where the action is. If it’s black or white, it’s pretty easy. Most of the stuff is in the gray area, and knowing how to navigate your way through that gray is where all the action takes place.” Nobles’ lecture reflected strongly on her 30-year career in ethics, compliance, privacy, and corporate governance. Over the course of that distinguished legal and corporate career, she worked for such multinational companies as Dow Chemical, Baxter Healthcare, Caremark, CVS, and BP. She has worked directly with corporate CEOs and boards of directors to provide strategic leadership to companies in the areas of governance, ethics, and compliance. Most recently, she was with Walgreens, where she served as Chief Compliance and Privacy Officer. The Leighton Lecture Series is sponsored by the Center for Professional Responsibility in Business and Society and the College of Business. This lecture series is underwritten by generous contributions from Richard (’49) and Grace (’50) Leighton.