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In , Dr. Previously, he served as president of Kroll Inc.

Frank Holder

Before joining Kroll, Dr. Holder was president of Holder Associates in Buenos Aires, Argentina, a risk mitigation and business intelligence firm.

Ethics and Integrity in Business

He began his career with the U. Air Force as a political-military analyst for the U.

He has taught courses in political science and law on the inter-American system at Universidad del Salvador, Buenos Aires, and has spoken and published widely on risk management, national security, operational risk and money laundering. Employees with regular computer access at work and employees in managerial and leadership roles must complete online courses on specific topics, and in-person training is made available to all employees to address Code-related issues relevant to their region.

His messages are supported by monthly presentations from the ethics and compliance team.

chapter and author info

We further embedded a culture of integrity into our personnel management practices by including conversations about our company values during performance evaluations and annual goal-setting meetings. We actively encourage employees to speak up and report any incidents where a possible Code of Conduct violation has occurred. Anyone — including contractors and community members — at any time can anonymously report a concern via the web or by phone using our third-party-run Ethics Solutions Tool available in English, Spanish and Dutch.

We also input into the Ethics Solutions Tool cases with a Code-related component that originated through other channels such as human resources or security.

Leadership Series

Any matters that have a human rights impact are categorized as such. Substantiated compliance issues lead to some form of action, which may include a recommended process improvement, coaching, formal discipline or termination. Managers are reminded of substantiated outcomes at mid-year and year end so that they can be factored into performance appraisals, thereby potentially affecting remuneration.


  1. Human rights and labor standards.
  2. High on You?
  3. Frank Holder!

During the year, we continued to assess our ethics and compliance program and identify opportunities for improvement. Areas of focus included strengthening our management of corruption risks, implementing stronger controls, engaging and training employees on relevant ethics matters, and conducting prompt, thorough and fair investigations.

Ethics and integrity

We significantly improved the management of commercial and government corruption risk throughout the lifecycle of our supplier relationships with the launch of our Supplier Risk Management program. During the year, we initiated a program to audit suppliers identified as high risk from a corruption perspective. As part of the program, each quarter our ethics and compliance team collaborated with our supply chain organization to identify vendors whose work might pose a corruption risk, and then the ethics and compliance team audited the relationship to determine whether it met our basic contracting requirements for bidding, contracting and vendor lifecycle management, and to evaluate the ethics and compliance practices of the vendor.

No significant supplier corruption risks were found; however, the audits did identify opportunities to improve internal processes and also served as an effective, positive engagement tool with suppliers. The new certification process led to a heightened focus on certain expenditures, and was supported by an expense management optimization effort to improve our cost-related reporting, specifically to enhance tracking of payments and expenses related to government officials and community leaders.

Following a third-party assessment in that evaluated the effectiveness of our global ethics program, in , we extended the assessment to our regions and operations. In , we plan to deploy a new online conflict of interest disclosure platform that reduces the need for paper disclosures and consolidates all disclosures, significantly improving our ability to analyze, track and manage any potential conflict of interest. In all our jurisdictions, we engaged with government stakeholders on key matters including the following:. These efforts and discussions will continue in along with developing relationships with a number of newly elected federal and state officials in the U.

FTI Consulting’s Frank Holder

At least 30 minutes of in-person Code of Conduct-related training was made available to all employees, and more than 90 percent of our employees participated in sessions during the year. In addition, those with a work-issued computer and email account were required to complete a comprehensive Code of Conduct online training program, and managers at and above a certain job grade were required to complete online training focused on preventing corruption. Participation in both online training programs was 98 percent.

A total of new issues were captured in our Ethics Solutions Tool during the year, and 78 cases were open at the beginning of the year. By year end, of those matters were closed and 55 remained open.


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Of the cases closed, 65 percent were not substantiated. Of the cases investigated, the vast majority 63 percent arose from allegations of misconduct or inappropriate behavior that often involved issues between employees and their managers. Around 19 percent of the cases arose from internal and external concerns about corruption including conflicts of interest, commercial and government issues , 11 percent were inquiries, and 4 percent were about environmental, health or safety allegations.