ADM’s Compliance Chief Ben Bard to Exit Amid Financial Reporting Crisis, Signaling Ongoing Challenges for Internal Controls

Archer-Daniels-Midland Co. (ADM.N), a global leader in agricultural and nutrition markets, has announced that its Chief Compliance Officer, Ben Bard, will step down early next year, citing personal reasons. The news arrives at a precarious moment for ADM, as the company struggles with escalating scrutiny over accounting issues that have forced it to delay regulatory filings and overhaul financial practices.

The timing of Bard’s departure is significant for compliance professionals, coming just one day after ADM requested an extension from the U.S. Securities and Exchange Commission (SEC) to file its third-quarter financial report. ADM’s accounting issues, which have involved discrepancies in reporting sales between its core and nutrition segments, have resulted in the restatement of six years’ worth of financial data, ongoing government investigations, and the resignation of CFO Vikram Luthar in September.

According to ADM spokesperson Jackie Anderson, Bard’s departure is unrelated to the financial irregularities, and any speculation otherwise “is factually inaccurate.” Anderson further underscored Bard’s valuable contributions over nearly a decade in steering ADM’s compliance strategy.

Bard’s departure underscores the challenges ADM has faced in strengthening its compliance and financial integrity frameworks, a scenario familiar to compliance professionals across industries. For organizations grappling with complex supply chains and diversified operations like ADM, sustaining rigorous oversight in both financial and operational compliance is vital but challenging—especially under regulatory pressure. ADM’s recent experience highlights several critical compliance takeaways:

1. Strengthening Internal Controls in Response to Regulatory Pressure: Following the uncovering of accounting irregularities, ADM has had to initiate more robust internal controls, signaling to compliance professionals the importance of preemptive compliance strategies. Ensuring thorough inter-departmental checks, particularly between core operations and specialized business units, can mitigate risks of inaccurate reporting and potential regulatory breaches.
2. Leadership in Compliance During Times of Organizational Change: Leadership continuity plays a key role in compliance stability, and Bard’s exit may be a reminder for compliance teams of the importance of succession planning and knowledge transfer. Organizations facing similar challenges might benefit from assigning a dedicated transitional team to sustain compliance integrity during executive turnover.
3. Transparency and Stakeholder Assurance: ADM’s swift steps to inform the SEC and request filing extensions also demonstrate the role transparency plays in managing regulatory relationships. For compliance professionals, especially those in publicly traded companies, open communication with stakeholders is critical when internal issues arise, as it can ease investor concerns and demonstrate the company’s commitment to resolution.
4. Enhanced Oversight Through Diverse Expertise: ADM’s recent board appointments—including AT&T’s General Counsel David R. McAtee II and new CFO Monish Patolawala, who brings experience from 3M—reflect an emphasis on incorporating broad expertise in governance. Compliance professionals should note the value of diverse, cross-functional expertise in navigating complex regulatory landscapes.

Addressing Compliance Gaps in a Reactive Framework

As ADM contends with these challenges, Bard’s tenure offers a complex legacy for the company’s compliance posture. Bard joined ADM in 2014 with a background in anti-corruption and trade sanctions at Coca-Cola, bringing industry expertise that had been critical during ADM’s expansion into international markets. However, the delayed recognition of internal control issues suggests that ADM may have relied too heavily on reactionary measures, with insufficient checks and balances across its divisions.

ADM’s case is a cautionary tale for compliance professionals about the dangers of underestimating proactive risk management. While ADM’s new appointments and control measures may help restore investor confidence in the short term, compliance experts know that sustained change requires a foundational overhaul. For companies managing sprawling operations, comprehensive compliance frameworks and regular, proactive audits are key to avoiding the pitfalls of reactive damage control and securing long-term stability.

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