After regulation: Finding balance in compliance - WeQual

After regulation: Finding balance in compliance

Posted by - Sean Smith

Published 14-04-2021

An exclusive interview with Holly Kulka, Global Chief Risk & Compliance Officer for S&P Global Ratings

When Holly Kulka arrived at S&P Global Ratings in August 2015, the company was just beginning to grapple with the storm of regulatory requirements growing out of the subprime crisis which had come into force in June of that year.  

“When I arrived at S&P, the company knew what the new regulations said, but it was in the early stages of figuring out how to embed the changes in the structure and culture of the organization. There was a lot going on – but it was a lot of noise and confusion,” she told WeQual Magazine exclusively.

“There was all this regulation, and a new leadership in Financial Services Regulators around the world, including at the SEC. My impression was that people wanted to do the right thing, but no one was sure exactly what that was, or how to think about the question in the absence of very specific guidance.

“The industry had originally been mostly unregulated, and then suddenly highly regulated. And global regulators were being added every year.” 

As Global Head of Compliance and Risk for S&P Global Ratings, it is Holly’s job to lead the company’s globally integrated risk and compliance teams, to ensure S&P’s compliance with all relevant laws and regulations, as well as complying with internal policies and industry best practices. 

“The way I like to work is to ask the question, ‘OK, what’s the problem?’ This is the theme I’ve always used. There is an enormous amount of work to be done, but you need to be able to work towards the future. When I arrived at S&P Global, I understood we needed to align ourselves to the regulation and make it work,” Holly added. 

“In the beginning there was so much noise and change I started asking people to differentiate between harm and pain. What was preventing the business from moving forward in the way that made sense and what was merely painful? I wanted to try and fix both, but we had to prioritize.”

S&P Global is the pre-eminent leader in credit ratings. For over 160 years, S&P Global has been turning information into insights, providing essential intelligence that accelerates progress in the world, delivering data, research, credit ratings, and ESG solutions that governments, companies and individuals depend on to make decisions with conviction.

There is a salutary lesson in Holly’s experience of helping S&P Global prosper alongside a tightening of regulations. In the next few years, the tech industry – particularly companies running social media platforms – is expected to see a ramping up of regulatory controls on their core operations. 

“In the beginning there was so much noise and change I started asking people to differentiate between harm and pain. What was preventing the business from moving forward in the way that made sense and what was merely painful? I wanted to try and fix both, but we had to prioritize.”

“Where there are scandals, it is not just about a lack of regulation – and regulation should not be the only solution,” Holly said. “As a company, you should not be thinking only about what you are allowed to do. You should be thinking about what you should be doing because that’s how everyone else is going to think.  

“Most companies want to be, and do, good. Most companies want themselves to mean something, that’s where you take that theory about what you want to be – your mission statement – and you apply it.”

When a company goes through a big shock, leadership on the way out of the crisis is crucial. Holly advocates a leadership style that stresses the importance of empowering people across the whole business, not just those who answer to you.

“Most companies want to be, and do, good. Most companies want themselves to mean something, that’s where you take that theory about what you want to be – your mission statement – and you apply it.”

“It’s a lot of things. You have to have empathy, for a start. And it’s also about being able to exert influence outside of your direct chain of command,” Holly explains. “It is no good if you can only be of influence within your own team – you need to influence the rest of the business. 

“It is important to be self-deprecating too,” she added. “Admit your mistakes and ask for help. A very important part of being a good leader is to be naturally understanding and able to acknowledge your own weaknesses. 

“Ultimately it’s all about the alignment and bringing everything together. To be a good leader you have to recognise the stakeholders and bring them all together. 

She added: “You also have to like people. You have to enjoy getting to know people and working with them. A big part of what you do as a leader is delegating and relying on other people.”

“What it comes down to is: when you are a lawyer you’re not just advocating, you’re also influencing. As an in-house lawyer I was used to influencing across the whole business. To me it was a relatively easy shift.”

While Holly’s background is in law, she found it a seamless transition into the commercial aspects of the business world.

“Having had a background as a lawyer, I always ask myself, when approaching a problem, ‘Is it really a case of yes or no?’ I’ve had a number of legal careers: I’ve been a public prosecutor, a law firm partner, and I’ve also worked as an in-house lawyer. 

“What it comes down to is: when you are a lawyer you’re not just advocating, you’re also influencing. As an in-house lawyer I was used to influencing across the whole business. To me it was a relatively easy shift.”

Ultimately, Holly explains, the crucial element to all of the last five years is alignment.

“If you were to dial everything down to one word – that word would be ‘alignment’. What are you doing with the business? What does the regulation require? What do the regulators need? It’s about aligning everything. 

“When it comes to how you do that, well, it has to be specific to your business,” Holly explains. “You need to align what you are doing with what the business is going to do – dial it down to the very specifics of your business and really apply it.”

“But you need to make it your own and be accountable. You can take a text-book scenario and apply it to your company, but it’s not always going to be relevant.”


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