Tyson Foods continues to evolve and adapt to everchanging conditions that include a growing global population and increasing demands for protein. As we do, we’re committed to continuing to live out our core values, which include operating with honor and integrity.
This applies to every country where we operate, where our policies must align with all laws and regulations, while respecting diverse cultures. In support of that, we are proud to announce Jane Duke has been named to the newly created position of Chief Compliance Officer for Tyson Foods.
In this role, Duke will oversee the company’s global ethics and compliance efforts as well as internal investigations. She will have the responsibility and authority to bring together all facets of Tyson’s operations to help ensure we are operating compliantly, with the right controls, policies, and oversight throughout the world.
Duke brings tremendous expertise as a seasoned attorney in a variety of roles, including a lengthy tenure with the Department of Justice where she served as a U.S. Attorney and in private practice representing companies and individuals involved in internal and government investigations, as well as complex litigation. She joined Tyson Foods in 2018 as a vice president and associate general counsel, leading a team of attorneys and other legal staff involved in managing domestic and international litigation.
Read on to learn more about Jane Duke and what she brings to this role.
Why is it important for Tyson Foods to have a Chief Compliance Officer?
Duke: The short answer is because individual leadership and overall structure are two of the things the Department of Justice considers when evaluating the effectiveness of a corporate compliance program. But there is a more fulsome explanation that better answers this question.
Operating with integrity is central to who we are as a company. That means every day, in every market and in every interaction, we live out our Code of Conduct, exemplify the 5Cs and hold our core values unassailable.
It also means we adhere to both the letter and spirit of the many laws and regulations of the jurisdictions where we operate. But understanding and navigating global regulatory risk is only half of the equation in solving for a robust corporate compliance program.
The other half is establishing and sustaining observable, testable, and replicable programs and processes that demonstrate a genuine commitment to compliance and drive a culture of compliance. That second half of the equation won’t just happen organically.
Achieving this kind of best-in-class program requires intentional effort. It requires a dedicated, adequately resourced and empowered compliance team. It requires a strong leader experienced in risk assessment and mitigation, regulatory constructs, investigatory processes and regulatory enforcement.
And it requires a leader with a singular focus of continuous improvement for business integrity who has access to, as well as accountability to, executive leadership and the Board of Directors. This is how we deliver value for our shareholders, our team members, our customers and our consumers. And that is why it is important for Tyson Foods to have a Chief Compliance Officer.
How will this role help enhance the presence of Tyson Foods both domestically and globally?
Duke: Today’s regulatory environment is complex. With our expanding global footprint, it’s imperative we understand all of the various legal risks present in our industry; and, that we stay ahead of regulatory changes on the horizon. This role helps ensure we’re in the best position to succeed in the global marketplace.
How will your team help set up Tyson Foods well for the future?
Duke: This is a great team that has benefitted from having highly committed leaders over the years. We look forward to continuing to partner with the business in all of the many ways we have historically done, such as social compliance audits, Code of Conduct training, third party due diligence, policy review and revision, disclosures and approvals and ethics case management. But in the spirit of continuous improvement, we are always striving to find better or more efficient ways to enhance the delivery of those services and welcome any input from our stakeholders in the business.
In thinking about the future, we can’t overlook the exciting possibilities technology and data present. We are actively looking for opportunities to incorporate the use of technology and data analytics in our ongoing and future work.
As far as new efforts, we will be building on already-existing enterprise risk assessments and using that work product to inform the preliminary design of our domestic and international regulatory compliance programs and training. We are extremely fortunate to have a wealth of subject matter expertise across the company in some highly complex areas such as food safety, food labeling, health and safety, environmental regulations, and data security.
As we dive substantively into forming up our regulatory compliance program towers, we will actively seek out and leverage this expertise.
How has your extensive background in law helped prepare you for this role?
Duke: Lawyers, particularly those with litigation experience, bring an additional trait to compliance of problem solving. In that regard, we want to help the business “get to yes” ethically and compliantly.
Additionally, while I won’t say that I’ve “seen it all,” during my 25 years of litigation and enforcement experience, I have seen and successfully defended or prosecuted a lot of diverse risk. From each of those matters, I have learned and grown as an attorney by studying the “miss” or the “gap” that launched the parties into an adversary proceeding.
Being a student of the gap forces you to focus on why something happened and how the consequences could have been avoided or mitigated. It makes you think about how a better risk assessment tool might have identified something early on or how a more robust compliance check might have caught something before a regulator did.
My work as a former prosecutor trained me to have a very critical approach to investigations and to really question things that others might take at face value. I was known for being very thorough and for getting to the truth of the matter. The other thing I was proud to be recognized for was my sense of fairness. I actually had a few defendants who thanked me at the conclusion of their case.
What most excites you about this position?
Duke: Without a doubt it is the fact that I get to be an integral part of building an enduring global compliance program that helps Tyson Foods succeed for years to come. I am immensely grateful to our General Counsel Amy Tu for giving me this opportunity and for the support of the Enterprise Leadership Team and our Board.
What is your most memorable achievement?
Duke: Being the lead special prosecutor over an extensive federal investigation of police corruption in Oklahoma. That multi-year investigation and prosecution taught me that finding the truth and doing what is right is not always easy. But to find the truth, you have to go where the allegations and evidence take you. At the end of the day, operating with integrity and upholding our promises are simply non-negotiables.
How has your upbringing impacted your career?
Duke: I grew up on a family farm in Arkansas as one of 13 children. My mother worked as a line production worker at one of Tyson’s poultry plants for 23 years. I am very proud of my upbringing because it gives me a unique perspective on the variety of issues that I deal with every day as an inhouse attorney for Tyson Foods.