Corporate Compliance plays a key role in fostering a culture of integrity by embedding ethical values into the company’s policies, decision-making processes and business execution !

Anghrija Chakraborty, our next pathbreaker, Compliance Counsel (India, Middle East and Africa) at The Lubrizol Corporation – a Berkshire Hathway company, provides advisory services on transactions involving anything from data privacy to anti-bribery and anti-corruption to anti-trust, labour compliance etc.

Anghrija talks to  Shyam Krishnamurthy from The Interview Portal about the impact of the legal field in enhancing trust and accountability; promoting fair competition; protecting workers’ rights; supporting sustainable development; mitigating risks of corruption and fraud.

For students, there are far too many options now. So, stop worrying about the future because “there is not one right way to get through life”. Take one step at a time !

Anghrija,  can you share your background with our young readers?

I was born in Bareilly (Uttar Pradesh), and raised in Ranchi (erstwhile Bihar, now Jharkhand). My parents were employed in a public bank, and I went to school at Bishop Westcott Girls’ School (nestled in the middle of the Namkom military cantonment area, for my ICSE), and then to DAV Jawahar Vidya Mandir (for my CBSE). I had always been interested in the dictates of social equity, justice, policy, ethics, doing the right thing etc., and therefore, in school, I was majorly active in the areas of debates, quizzes, elocution, public speaking, volunteering and other related activities.

What did you do for graduation/post graduation?

I studied Literature and Law.

After school, I began to consider what to do next. In a family of largely doctors, engineers, and management graduates, I bucked the trend and made the decision to study English Literature and then Law.

What were some of the key influences that led you to such an offbeat, unconventional, and unique career in Corporate Law ?

I genuinely found Law fascinating. Therefore, it was an easy decision to pursue Law. Of course, there were several other reasons – (i) I could represent myself in court if push came to a shove; (ii) because movies and TV series gave me no choice (read, Ally McBeal, The Practice, etc.); and (iii) because I wanted my grandparents to have something nice to tell their friends.

It is hard to explain what I learned at law school. I did not learn how to design a building or cure a disease. I learned how to navigate the many invisible lines in the sand that made up the accepted rules and behaviours in society. Law school helped me to identify the scientific method, in that you ask a question, carry out research, construct a hypothesis, test the hypothesis and draw conclusions based on the results. Law is a product of this same process – however, in core law subjects we consider this process in reverse. We start with the legal rule, read the cases that have tested it, then perhaps the jurisprudence and policy that explain the academic and research perspective of the rule, and, lastly, the social wrong or problem which posed the question in the first place.

Also, you learn to differentiate between a fact and an opinion, and then between a conclusion and an assumption. This makes us discerning and compelling. It also gives us the skills to contemplate the vast ocean of media that drowns us day to day. The rules of admissibility and evidence are not only useful in the courtroom, the habitual cognitive practice of considering “hearsay”, “relevance” and “fact over opinion” when gathering our thoughts allows us to be more concise, effective and persuasive communicators. Conversely, it also equips us with the ability to think critically when we are being communicated to.

As law students, we learn not to think in isolation and write manifestos and treatises fit only for academia. We are on the ground, thinking and contributing to very real discussions and responding to very real problems.

Tell us about your career path

At the Cowen Law Group, with whom I started my career, I was mostly involved in pre- and post-litigation in the torts space. My experience here was helpful in developing both technical and practical legal skills. Tort law includes areas like personal injury, medical malpractice, and product liability – so my experience at the Cowen Law Group was helpful in gaining experience across various legal scenarios.

At Pangea 3 (A Thomson Reuters Company – now part of EY) – I managed the regulatory compliance team, and my expertise lay in client relationships management, and international regulatory compliance.I demonstrated success in establishing compliance solutions as well as rapidly scaling teams across locations. My specialties included: US, UK, Canada, APAC banking compliance (data privacy, securities, AML, SOX, GLBA); insurance (HIPAA); retail, heavy engineering, power, oil and gas, manufacturing industries’ regulatory compliance; KYC due diligence; obligations management; sales; client relationship management; coaching/mentoring; team development; budgeting; project and program management; RFPs, etc. In addition, I assisted the Learning and Development team at Pangea3 in training on topics such as attorney-client privilege, work product doctrine, US Federal data privacy laws, and best practices about client engagement. During my tenure at Pangea3, I received several awards: Employee of the Month, May 2011; Employee of the Year (Passion for Work), 2011-2012; Employee of the Year, 2012-2013 (this was in recognition of my role in getting business from one of the biggest US home décor and appliances stores, and from a giant in financial services).

PricewaterhouseCoopers (PwC India): At PwC, I was responsible for outlining regulatory requirements and system changes for product managers and developers, and monitoring development, through implementation. I provided regulatory updates to clients, outlining both rule requirements and system changes, and partners with compliance, operations and technology leaders at clients’ end to gather requirements for meeting regulatory changes. I, either at the direction of senior management or independently, led regulatory calls with clients, workshops and conference panels. Finally, as co-sponsor with product managers, I conceived, developed and implemented strategic system enhancements in support of regulatory requirements and clients’ evolving needs. During my time at PwC, I was managing the team that won the biggest GRC project from a global ITeS giant in the history of PwC at that time.

Aricent Technologies (Altran NA, and now part of the CapGemini Engineering Group): At Aricent, my chief duties were planning, implementing and monitoring all ethical and corporate compliance programs. Co-ordination of compliance audit activities and communication of expectations and reporting results were the key functions of my position. My responsibilities included: drafting compliance procedures and work instructions from the ground up; regularly liaising with internal legal counsel to ensure operational compliance with all relevant laws and regulations; analysing information as well as questioning and investigating results from compliance reports; managing compliance operations; setting employee standards of conduct and clearly relaying to staff what is expected of them; carrying out assessments (including fraud risk assessment, etc.) to determine the effectiveness of any corrective actions; monitoring internal policies and procedures; developing test plans; looking out for any financial conflicts of interest; initiating corrective actions for the resolution of problematic issues; monitoring critical compliance risks issues; and overseeing any audits carried out by an external auditing firm. I was also a member of the ICC and regularly helped investigate/resolve cases that fell in the ambit of the India Prevention of Sexual Harassment Act, for the Aricent offices in Gurgaon, Pune, and Noida. Additionally, I was a member of the Investigations team that took care of all ethical and Code of Conduct violations at Aricent. I also wrote regularly on issues of data protection, harassment at the workplace, etc., and was a speaker at conferences and other platforms. During my time at Aricent, I won the CEO Award for Managerial Excellence for my deft management of the EU GDPR Implementation Program and the Third-Party Risk Management Program. I also co-authored a book on global data privacy legislation during my time between Aricent and AstraZeneca.

AstraZeneca: I assumed the role of Compliance Business Partner at AstraZeneca’s Global Hubs in Bangalore and Chennai, as well as the APAC Regional Supply sites (Bangalore, Cikarang and North Ryde). In this capacity, I provided expert guidance to leadership, managers, and colleagues on ethical decision-making, focusing on critical areas such as data privacy, cybersecurity, information security, conflicts of interest, anti-corruption, anti-trust, third-party engagement, and the responsible use of AI. I was also deeply engaged in mental health, inclusion, and human rights projects/engagements, and actively contributed to various Employee Resource Groups within AstraZeneca. I led the Living Wages initiative at AZ, was part of the Core Team of the Global Ethics and Compliance Inclusion & Diversity Forum and led the Safe Space (Mental Health) India ERG. During my time at AZ, I have won the 2024 Annual Global Ethics & Compliance Award for Ethical Culture (elevating Inclusion & Diversity); an Honorable Mention at the 2023 Annual Global Ethics and Compliance Awards for executing an inclusion assessment for the function; and the 2022 Annual R&D Oncology Award for Inclusion and Diversity

How did you get your first break?

My first break came with a US based Cowen Law Group where I assisted with their strategic objective by ensuring that litigation documents were generated and reviewed so that the firm could aggressively and speedily prosecute its cases. I drafted pleadings, discovery requests, responses, letters to defense counsel, motions, and other pre- and post-litigation documents. I got my break with them via a job portal on which they had put out the requirement.

What were some of the challenges you faced? How did you address them?

Challenge 1: Gaining legitimacy within the company – Secure visible and vocal backing from top leadership; foster a culture of integrity by embedding ethical values into the company’s policies, decision-making processes, and training programs; regularly communicate the value of compliance programs to all employees.

Challenge 2: Keeping up with the regulatory changes – Establish horizon scanning teams to track regulatory updates and do risk impact assessments; regularly update employee training materials to reflect new regulations; engage consultants or attend industry events to gain insights into best practices for adapting to regulatory shifts.

Challenge 3: Combatting cultural indifference – Encourage leaders to model ethical behaviour; use engaging training methods to make ethics relatable and actionable; implement clear policies with consistent enforcement and recognition programs for ethical behaviour.

Where do you work now?

I work at The Lubrizol Corporation – a Berkshire Hathway company – as Compliance Counsel for India, Middle East and Africa.

What problems do you solve?

I am involved in advising as well as transactions involving anything from data privacy to anti-bribery and anti-corruption to anti-trust, labour compliance, supply chain compliance, trade sanctions, etc.

What skills are needed for your role? How did you acquire the skills? 

Project management, business management, relationship development, strategic understanding, enhanced communications skills.

Companies invest in their people. I have received fantastic training in all the places that I have worked at. I have received a lot of one-on-one time with seniors, learning from their experience. Everywhere I looked across, there were bright, talented people and wherever I needed help or I had a question, there was a rush of people wanting to help. To have that sort of knowledge and experience essentially at your fingertips is phenomenal.

What’s a typical day like?

In-house lawyers and compliance specialists also get to flex outside of the law, and may assist in company secretarial duties and initiatives to cut costs or time to access legal services. I like to call it “cheerleading efficiency.”

Of course, this all sounds pretty peachy. It isn’t always like that. Sometimes I work long hours. However, the flexibility is good. As I am an early riser, I am in office quite early, and can leave with a little daylight left to satisfy me. Calls with the US are either early in the morning, or early in the evening, and Europe comes after lunch. There is plenty of time for mind-calming yoga or reading in the early evenings.

What is it you love about this job?

I have not seen many cons so far. I have gained invaluable experience with stakeholders at all levels of a business. I have learned that “no” is not an option (alternative solutions are always welcome though). And, there is access to a never-ending supply of varied legal matters and projects.

How does your work benefit society?  

Upholding legal and ethical standards; enhancing trust and accountability; promoting fair competition; protecting workers’ rights; supporting sustainable development; mitigating risks of corruption and fraud.

Tell us an example of a specific memorable work you did that is very close to you! 

The R&D Oncology Annual Award 2022 at AstraZeneca – The voluntary mental health awareness employee group partnered with Global IT and Microsoft on a global mental health support solution for all AZ and Alexion colleagues across all AZ countries in 24 languages. The HealthyMind app, accessed by 8,000 staff every month, helps staff manage their own mental wellbeing and brings together in one place all the on-line mental health support currently available across our internal channels, which may not have always been obvious how or where to access.

Your advice to students based on your experience? –

There are far too many options now. All I would say is that students should relax and not worry about what others are doing. There is a lot of pressure on later year law students (and much of it is self-inflicted) to have a clear career plan after graduation. In reality, nothing could be further away from the truth. The best piece of advice anyone has ever given me was to stop worrying about the future because “there is not one right way to get through life.” Ignore what everyone makes you think you should achieve in your career/life by forging a unique path. I actually took a year’s break during law school, before I finally completed. In that period I did not lose pace with my peers, nor did I have challenges in starting again where I left off or while starting my career, but I did gain the world.

Future Plans?

 Write more books. Open a bookstore that serves coffee and the likes – and have a bunch of “abandoned” animals that I can take care of.