Leading by Example - The Business of Corporate Ethics

While the Galleon news has primarily faded into the backdrop of the media landscape, its impact continues to pervade the financial services industry in myriad ways from a heightened focus on compliance to an increased spotlight on insider trading and the exchange of critical, sensitive and material non-public information. This single breach clearly illustrates the enormous impact one single employee can have on ruining the trust a company has spent so many years building with its clients, the financial services industry and its employees.


27 January 2010

While the Galleon news has primarily faded into the backdrop of the media landscape, its impact continues to pervade the financial services industry in myriad ways from a heightened focus on compliance to an increased spotlight on insider trading and the exchange of critical, sensitive and material non-public information. This single breach clearly illustrates the enormous impact one single employee can have on ruining the trust a company has spent so many years building with its clients, the financial services industry and its employees. Despite this new level of appreciation, three months later, what has Galleon truly taught us? Intralinks deals with confidential business information by design, therefore making security our top priority when it comes to managing our technology and personnel. It’s all about keeping the trust we’ve spent more than 12 years building with our customers, including those in the financial services community, and with our employees. It is our duty to safeguard our clients’ most valuable asset — their information. Our business is based on earning and maintaining our customers’ trust in managing their critical, sensitive business information.

The significance and value of information varies from one person to the next. Whether spoken or written, the transference of one person’s knowledge ultimately opens an opportunity for the recipient to determine the price associated with that knowledge.

Let’s look, for example, at a board member of a blue chip company who knows the company’s projected revenues in advance of the quarter’s close. While the board member may find this financial data only intrinsically worthwhile, in the hands of a stockbroker this same information could easily lead to insider trading. What that information means to consumers, other businesses, and government — adds another layer of complexity to just how valuable it can be.

This can make it difficult to know where to draw the line — what to say or not to say in business situations where sharing information on a project may seem routine, or in a meeting with investors where company data needs to be discussed.

As Intralinks’ CEO, it’s critical that I provide my employees with a roadmap to ethically responsible behavior. Security and trust is at the heart of our company, our technology solutions. Helping customers safely exchange critical information with their specific compliance and business needs in mind is the top priority for every Intralinks employee 24x7x 365.

Beyond maintaining our secure technology platform, what do I do to ensure that our employees preserve the trust we’ve worked so hard to build with our customers? At our company, we hold management meetings and e-learning seminars to clearly outline concepts like “material, non-public information” for those who may not think this applies to them, and for starters, screen all of our employees and have them sign NDAs. I have a monthly “All Managers” meeting where I’ve brought this subject up in the past and will continue to do so in the future. Our customer’s confidential information is treated like our confidential information. These actions are normal and a necessary course of business for a company that is in the business of protecting and securing our customers critical information.

We’ve all seen companies learn the hard way; it only takes one person to say something that not only puts their own job at risk but can ultimately have a broader impact on an entire company. While Galleon is just one recent example, more companies need to lead by example and coach employees on what it means to be an ethically responsible person to both their own company as well as its customers. It all starts at the top; it must come from the Board of Directors to the CEO to the Executive Team and down through the entire organization. Because at the end of the day, it’s all about keeping the trust we’ve spent so much time building with our customers and with our employees.