For example - all emails to above go through compliance first & include a disclaimer that you are a market participant and do not wish to receive MNPI. Meetings with above have compliance sit in, etc. People are urged to self report if someone does volunteer something stupid to you that they shouldn't have, and then you sit out from trading it for some period, etc.
They make it very clear that the upside/downside risk is asymmetric. Hey maybe you can cheat and make 10% more this year. Or you can go to prison for 10 years, lose your home, have your wife leave you, and never work in the industry again.
you can go to prison for 10 years
Raj Rajaratnam is one of the most notorious in the current generation. He only did 7.5 years. And Stephen Cohen had so many layers in his onion legal strategy that SEC could never nail him down.
It’s like an investment banker back in 2006 saying that he was doing everything by the book, which he might of well have done, but the whole thing was crooked nevertheless.
that's fair - did they also provide training on actually not violating anti-trust regulations, or was it just how to avoid leaving evidence of violations?
The additional rank-and-file training and process that ties into actual anti-trust-related behavior is how to contact a lawyer as well as the fact that a lawyer and executive needs to review and approve all of the most minor of launches.
Do you have an idea of what the relevant training you would prescribe for a random mid-career engineer or UX researcher or whatever would be?
If they can develop training that says "don't say bundle", they can develop training that says "don't bundle", and in both cases they might want their employees to talk to a company lawyer if they have any questions anyways
also curious if the lawyers themselves had rules like "don't bundle" that they would pass along to employees with questions, or if google was okay with bundling
I got the same takeaway when I was at Google as when I was in the hedge fund space: be careful what you say, regulators and judges might not be very charitable. In both cases, the concept of something you say being in the New York Times was present for me.
The Googlewide training and messaging when I was there did focus on not using anti-trust-triggering _language_ over the specific acts, but I don't think it's fair to interpret this as "Violate anti-trust regulations" but rather a recognition that the common fuck-up some random employee can make isn't to commit a material anti-trust violation, but to provide nasty evidence by writing a puffy email about "crushing the competition". Telling people to write emails about "making users happy" rather than "owning the market" is not telling people to behave badly.
I don't know what you're doing in finance, but it's my understanding that folks who are actually involved in stuff where their job could look like insider trading probably do get subtler lines drawn than I ever sought (I was in systematic/program trading.) Places where doing my job well could be confused for something bad, e.g., tax optimization, we did discuss how to properly communicate in order to avoid misunderstanding if a regulator, court, or journalist ever read our communication.