12 ACC DOCKET’S TOP 10 30-SOME THINGS | A SPECIAL SUPPLEMEN T OF ACC DOCKE T
2017 TOP 10 30-SOMETHING
SAN JOSE, CALIFORNIA
Accenture is a leading global professional services company, providing a broad range of services and solutions in strategy, consulting, digital, technology, and operations. Combining
unmatched experience and specialized skills across more than 40 industries and all business
functions — underpinned by the world’s largest delivery network — Accenture works at
the intersection of business and technology to help clients improve their performance and
create sustainable value for their stakeholders. With approximately 401,000 people serving
clients in more than 120 countries, Accenture drives innovation to improve the way the
world works and lives.
To maintain its ethical reputation, it’s important for the company to maintain a strong
culture of ethics and compliance, including robust compliance programs like anticorruption
and government compliance. One key component of Accenture’s approach is to conduct due
diligence on its third party business partners. After all, nearly 90 percent of problems arise
out of a third party agreement. Dan Seltzer, the company’s senior director of anticorruption
and government compliance, saw an opportunity to streamline and enhance Accenture’s
compliance due diligence program. “Doing more with less” is a phrase all in-house counsel know well. Few are able to create a program that delivers a superior product while also
reducing the report time from 33 days to three days and reducing company spend by 90
He leveraged Accenture’s internal legal network, a truly global operation, to set up a test
for its outside due diligence vendors. He assigned 10 lawyers in India to the due diligence
team, trained them for six months, and compared the team’s results with the vendors’.
There wasn’t a single instance of the internal team missing a possible red flag. In fact, the
Accenture team caught 20 percent more material than outside vendors. Seltzer sums up the
The project wasn’t without its risks however. Seltzer and his legal department had to
balance the gains against the likelihood that the team could miss something during due
diligence. “The idea was that we would not be reliant on an outside vendor to have some
unknown person in their company running the reports. Instead, we can track it ourselves,
and if there are issues, we can figure out if the person needs additional training and address
it,” he explains.
Seltzer’s solution — which mirrors Accenture’s approach — is emblematic of his style
of problem solving. That is, most problems require a unique solution. Accenture specializes
in them. Seltzer took the same approach when he designed the company’s anticorruption
compliance trainings. Most employees receive an annual computer-based training. The
employee answers questions that determine their understanding of anticorruption law that
then generates a personalized training document that focuses on specific knowledge gaps.
For higher risk locales (Accenture operates in 120 countries), he tailored a custom live training program that is delivered in person by local lawyers. The goal of his style of training, he
says, is to reinforce the idea that it’s OK to ask a question. He’s found that when a real world
scenario is presented, there’s an uptick in questions about ethical behavior.
It’s exactly the kind of lesson that makes Accenture what it is. The ethical, behind-the-scenes company is made up of ethical, behind-the-scenes employees like Seltzer. 30