Corporate Counsel Corner: Shell's Anne Riley

Oct 21, 2011

 CPI Executive Board member Danny Sokol continues CPI's new Corporate Counsel Corner feature; a series of interviews highlighting the corporate viewpoint on dealing with antitrust issues.

Our second installment features a conversation with Anne Riley. Anne is Associate General Counsel at Shell International. She has practiced antitrust law for Shell since 1982 and serves as leader of the global antitrust team. One of Anne's responsibilities includes developing and maintaining Shell's antitrust compliance program. Danny taps into Anne's experience with Shell's dedication to compliance, and then elicits Anne's insights into antitrust compliance for businesses generally.

The conversation begins with how Shell has a built a solid base for compliance by enshrining ethical behavior within its Code of Conduct. Anne elaborates by discussing the business principles essential to Shell's success with compliance: Shell seeks to compete fairly and ethically. Danny picks up this theme by asking Anne to share her thoughts on how a GC captures the attention of the business unit to treat antitrust compliance seriously.

Expanding beyond Shell, Anne shares her views on the obstacles compliance enforcers face in the global arena, where there are conflicting antitrust positions depending on the jurisdiction. Anne debates the approach of setting common standards to apply them consistently, and identifies when such an application runs up against difficulties. She pinpoints the "greatest challenge across different legal regimes," but proposes a workable solution to this problem.

The interview wraps up with Danny's query on how competition agencies can improve compliance. Anne recommends better advocacy not just in the business community, but also in the public at large. Promoting advocacy can make antitrust compliance more than a government regulation and transform it into a societal norm. Related to this prescription is better coordination and dialogue between businesses and agencies, to ensure that the latter is not sending mixed signals with regard to competition and enforcement. The key is again to promote advocacy instead of punishment as deterrence.


To hear the full interview, follow the link below:

Danny Sokol and Anne Riley interview

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