Pat Gnazzo, senior vice president of CA, Inc, dined with 12 students in March, as part of the Paul M. Montrone Seminar Series on Ethics during Columbia Business School's Leadership and Ethics Week. Mr. Gnazzo has been the chief compliance officer of CA, Inc (formerly Computer Associates) since January 2005, prior to which he was the chief compliance officer at United Technologies Corporation (UTC) for 10 years. The roundtable discussion with EMBA students and Professor Ray Horton, covered a range of topics from Mr. Gnazzo’s business experience and in the Navy. He led a discussion on how a corporation manages during a compliance crisis and how to design a compliance program. He first defined compliance’s role, focusing on the importance of the compliance function being independent of the management but at the same time having an executive position in the company. He cited his own position, in which he reports directly to the audit committee, as an example. At the same time, Mr. Gnazzo highlighted that the compliance function must be fully knowledgeable of the business of the company. To expect the company’s officers to be compliant with policies and procedures, the compliance function must fully understand the business of the officers. In answer to a question about students evaluating ethical standards in a company during recruitment season, Mr. Gnazzo spoke about the impact of a company’s focus on internal controls, internal audit and the compliance function as a determining factor of a successful company. Gauging the culture of a company can be difficult, but asking an interviewer questions and speaking to employees about the company can offer tremendous insight. Mr. Gnazzo gave instances of company guidelines that would prevent employees having to make judgments in gray ethical areas – CA, Inc’s strict acceptance policy strictly prohibiting giving or taking gifts of more than $200. He also explained sections of the Sarbanes-Oxley Act and said that these legislative provisions are an important step in preventing corporate wrong-doing. However, the costs of compliance are immense for smaller public companies. A highlight of the conversation was when Mr. Gnazzo spoke about some of the problems faced by CA, Inc during its accounting scandal and described the structure put in place since that time.