The Courage to Transform Investigations

What happens when you stop treating investigations like a black box — and start treating them like a tool for cultural transformation? Scott Sullivan, former Chief Integrity & Compliance Officer at Newmont Corporation, the world's largest gold mining company, did exactly that. The result: a 385% increase in reporting over four years, a radical rethinking of speak-up culture, and a model for how ethics and compliance leaders can build trust with the entire organization — not just manage risk for the few. In this episode, Scott breaks down how the 2021 Rio Tinto report on workplace behavior prompted Newmont to lift the hood on its own investigations process, how shifting from "speak up" to "ask, listen, act" moved accountability to leadership, and how the Organizational Justice and Integrity Dashboard (OJID) gave employees and executives alike a clear, honest picture of what was actually happening inside the organization. He also makes a case that culture doesn't have to be expensive. It just takes guts — and the right allies. If you're a compliance leader looking to drive real culture change, this one is worth your full attention. Chapters (00:00:00) - Opening and Intro(00:01:01) - Transitioning organizational culture by adopting radical transparency(00:04:00) - Building an organizational justice integrity dashboard to measure results(00:06:09) - Dealing with a nearly 400% increase in reporting overnight(00:07:20) - How to gain leadership support and internal allies for bold E&C initiatives(00:09:35) - Improving culture doesn't take money, it takes guts(00:10:52) - The best part about working in ethics and compliance