FOR THE RECORD
ROY SNELL
Bojan Bajic Discusses How
Compliance Continues to Spread
and Intensify Overseas
Roy Snell is the chief executive officer
(CEO), co-founder, and first president of
the 9,000 member Society of Corporate
Compliance and Ethics and Health Care
Compliance Association. He has written
over 100 articles, edited two manuals
and three magazines, and published a
book for compliance professionals.
He is an outspoken advocate for
compliance professionals and a
fierce promoter of compliance pro-
grams. He is a former University
of Wisconsin compliance offi-
cer, consultant for Deloitte and
PricewaterhouseCoopers, and
Mayo Clinic administrator.
He has a Master degree from
St. Mary’s college. His email address is
Roy.Snell@corporatecompliance.org.
Journal of Health Care Compliance — January–February 2018
B
ojan Bajic is chief executive officer (CEO) at
Net Consulting Ltd. in Sarajevo, Bosnia and
Herzegovina, and can be reached at bojan.bajic@
netconsulting.ba.
Snell: What caused you to become interested in compli-
ance in the first place?
Bajic: I have to admit that my first choice was not in
compliance because I was more interested in various
development projects and I even pursued a career in
politics. But I soon realized that I wasn’t able to create
more success stories because of the low ethical standards
in this post-conflict, transitional period in Bosnia and
Herzegovina and the former Yugoslavia. I understood
that I would either have to leave here or I would have
to work toward change to see my personal ethical and
compliance standards implemented within our society.
So instead of packing my bags and leaving like many
have done, I decided to try and change the world around
me … and focus on ethics and compliance. If this was a
normal, democratic country, I would probably not be
working in compliance but most likely in development.
Snell: You held the first ever compliance conference in
Eastern Europe. What was that experience like for you?
Bajic: Perhaps it would be better to say the first com-
pliance conference in the Western Balkans. The expe-
rience was quite stressful. We saw from the beginning
that not many were interested in accepting ethics and
compliance standards. So, we decided to bring people
together to see if we could spread the culture of ethics
and compliance in the Western Balkans and try to drum
up interest in this field. We were surprised and excited
that over 60 businesses, institutions, and other interested
organizations came together to talk about issues around
35
 For the Record
compliance. People were very pleased
with the conference, and it gave us wind
to our backs to continue promoting ethics
and compliance here in the region. I must
say that Roy Snell’s presence contributed
greatly to the success of the conference
and gave it even more legitimacy by bring-
ing one of the world’s most eminent and
respected ethics and compliance experts.
Snell: How did you get a law established
for whistleblower protection in Sarajevo?
I would think that would be difficult as a
citizen.
Bajic: Everything started when I met
Bosnia’s famous whistleblower, my current
colleague Visnja Marilovic, who reported
a $2 million corruption scandal in a pub-
lic company. She was exposed to a very
aggressive retaliation, and as a member of
a small advocacy NGO, I thought that the
best way to save her from this dilemma
was to turn this unfortunate incident into
something productive. So, we joined forces
and lobbied for the first whistleblower laws
in Bosnia and Herzegovina, which will
help and encourage others to continue to
report violations and corruption. We liter-
ally knocked on doors of our politicians,
talking to them about the issues, and tried
to drum up support. We were able to pass
the first whistleblower laws in all of Europe
with pre-court protection. This model was
introduced to us by a Washington D.C. law-
yer, Stephen Cohen. He told us this would
be the best option. We had no idea it would
be the first law of its kind in Europe … if
we did, we probably wouldn’t have had the
courage to be as assertive as we were.
Snell: How did you get the Ministry of
Defense to implement a compliance pro-
gram hotline?
Bajic: We were the first to make an anti-
corruption hotline for public institutions
and private companies in BiH. We knew
that only a small handful of ethical leaders
36 Journal of Health Care Compliance — January–February 2018
would accept this idea … as most politicians
and leaders would not even meet us to talk
about the hotline. We convinced Zekirajah
Osmic, the Minister of Defense at the time,
that the best way to demonstrate ethics and
to gain public trust was to have this com-
pliance mechanism in place. The Minister
decided it was a good idea to adopt our
program for internal investigations within
their own inspectorate and compliance
officers. An ethical leader decided that
being that he was clean and did not have
a “dodgy” background, there was no reason
not to implement this program.
Snell: What has been the biggest challenge
getting people to implement compliance
programs in Sarajevo?
Bajic: The biggest challenge is the political
environment and support for fighting cor-
ruption. Even the business community is
handicapped because in an environment
where there is so much corruption and no
fair play market it becomes commonplace
for many to participate in compromised busi-
ness practices. It’s not difficult to find ethical
leaders, but we also can’t expect every ethi-
cal leader to be a Don Quixote. That’s why
our biggest challenge is to shift the mind-set
in this highly charged and corrupt political
climate. We need a head shift here … that
would start to solve a lot of our problems.
Snell: What other countries in Eastern
Europe are implementing compliance
programs?
Bajic: Currently, we have the situation
where many countries in Eastern Europe
are adopting whistleblower laws and fight-
ing corruption in the public sector … but
there isn’t yet an effective set of mecha-
nisms that brings all of these components
together. We don’t know any country that
has adopted a comprehensive set of regula-
tions and laws that will effectively address
the complex issues of compliance. The
region needs to do a lot more in nurturing
 For the Record
the compliance culture to improve the
business and investment atmosphere in
the entire region.
Snell: What can you tell us about the future
of your government’s interest in compli-
ance programs?
Bajic: It’s interesting that at many levels
of government here in BiH there are lead-
ers that, after we present what compliance
programs are and the effects they can have,
are interested in implementing western cor-
porate compliance and ethics standards at
the public sector level. They are becoming
aware that businesses cannot effectively and
ethically operate/function without govern-
ment institutions behaving in the same way.
Snell: Do you think compliance programs
can help fight corruption in other parts of
the world?
Bajic: As I mentioned earlier … the reasons
why I got involved in this, where there is
not equal opportunities for all and where
corruption and bribery is the first and
main option instead of behaving ethically,
countries in transition need ethics and
compliance at the public level as well as
the corporate level. This is where we see
our experience having a widespread effect.
We have formed a new nonprofit organi-
zation called WEFEC — West East Forum
for Ethics and Compliance — to introduce
best practices from corporate compliance
and ethics from the United States into
the public sector of developing countries,
particularly in the “east” like the Western
Balkans, Caucasus’, and Central Asia. The
geo-political struggles tug-of-war in these
regions are directly correlated to the lack
of compliance and ethics … and this is
where we believe we can make a meaning-
ful change so that we can live in moral and
ethical societies. We know there are great
obstacles in spreading compliance in the
developing world, but we feel being that
we come from a post-conflict transitional
Journal of Health Care Compliance — January–February 2018
country that we understand the dynamics
and culture of corruption and nepotism
perhaps better than westerners. We hope
to bridge that gap between West and East
culture of compliance.
Snell: Do you think you would ever run
for political office again, and if you did,
would you make compliance a part of your
campaign?
Bajic: At this point and time I don’t believe I
would get involved in politics again. Ethics
and compliance has so pre-occupied my
life that I think compliance is a universal
idea to upgrade our civilization to the next
level. I hope this will become the dominant
idea in rampantly corrupt countries … and I
think it’s a worthwhile professional choice
to work in this field. The only thing that
would bring me back to politics, however,
because I’m convinced it’s our biggest and
most crucial problem, is because we don’t
have more compliance and ethics stan-
dards and practices at all levels.
Snell: If you could change anything in
Eastern Europe to make the implemen-
tation of compliance programs go faster,
what would it be?
Bajic: To bring compliance laws with included
compliance programs and compliance offi-
cers to public and government institutions.
Without this level of integrity and respon-
sibility, it is unrealistic to ask the business
community or civic society to behave differ-
ently. Compliance laws give effective instru-
ments to enforce anti-corruption laws, and
these need to be our focus. That would bring
Eastern Europe out of its current quagmire
and even make us a leader in compliance
laws within the public sector.
Snell: Who are some of the people you have
learned about compliance from?
Bajic: We have learned and read from many
people … but Roy Snell from SCCE has been
37
 For the Record

the most responsible for shedding light on
our specific situation where we are basically
a non-compliant country and that someone
understands our dilemma and has practical
solutions to our problems that are very dif-
ferent from those facing western countries.
Roy has definitely helped shape our world-
view on compliance and ethics.
Snell: What plans do you have for the next
five years?
Bajic: After several years of working in the
field of compliance, I have decided to focus
my energy on taking the best practices eth-
ics and compliances laws for corporations
and implement that effective mechanism
in the public sector for transitional and
developing countries — basically making
compliance the dominant idea in countries
struggling between West and East. This will
not only bring integrity but, I believe, also
prosperity.

38 Journal of Health Care Compliance — January–February 2018

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