Welcome back to the podcast, bribes, swindle, or steel.

I'm Alexander Raghi, and today we're talking about creating a culture of compliance.

My guest is Jonathan Drimmer.

Jonathan is currently the chief compliance officer of Barrick Gold.

The company is based in Toronto with mining operations and projects

in 15 countries. Prior to joining Barrack, Jonathan had a long stretch with a major law firm,

and he'll be returning to that world in Paul Hastings' Washington office later this month.

Jonathan, thanks so much for joining me. Thank you, Alexander. Pleasure to join.

Why don't we start, if you would, by describing what a culture of compliance looks like.

Are there characteristics that we can identify, or is this really a matter of knowing it when you see it?

Really, when it comes down to a culture of compliance, I guess it's best to start with why do we care about it? And the

reason we care about it is it goes to the core of how it is we get people to comply, how it is

we get people to do what it is we want them to do consistent with our policies and procedures,

which hopefully track legal requirements and the overall set of company

values. And traditionally, companies had, and this includes Berwick and others in the extractive

space, relied heavily on rules, rules-based processes to generate people to follow the direction

that ultimately we want them to go. And increasingly,

as we've seen and tested programs to determine effectiveness, what we've discovered is that culture

is as or more important than the rules themselves. And we talk about culture of compliance,

what we really mean is an overall environment that's fostering

ethical behavior, instilling in every employee the understanding and the obligation to do what's

right regardless of what the law says, regardless of what the rules say, regardless of who's

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