The Legal Department

Level-Up Ethics And Compliance By Putting People First: Jen Brewer, ActivisionBlizzard

The Legal Department | Jen Brewer | Ethics and Compliance


Activision’s Chief Ethics and Compliance Officer Jen Brewer is in The Legal Department to share her experience leading a global ethics and compliance function. An award-winning corporate governance and compliance professional, Jen led a cultural transformation at Activision Blizzard and engaged 140+ “heroes” in the company to promote a culture of openness, transparency, and listening. In this episode, she talks about how to build trust after crisis, how to work with diverse teams, and do the right thing for the culture and the company. She shares why patience, understanding, and listening are key ingredients to a functional culture and why transparency is the new imperative in investigations. And like Sia, Jen is “Unstoppable” facing any challenge.

Listen to the podcast here


Level-Up Ethics And Compliance By Putting People First: Jen Brewer, ActivisionBlizzard

In this episode, I’m excited to finally welcome Jen Brewer, the Chief Ethics and Compliance Officer of Activision Blizzard, to the show. Jennifer, how are you?

I’m good, Stacy. Thank you.

Thanks so much. We met through a third-party friend at an event, but we’re also kind of neighbors-ish. We both moved from LA up to the Central Coast so we have a lot in common. I’m excited to talk more about our roles. How’s it going down there in Ojai?

It’s good. It’s a little bit cloudier than I would like this time of year and that’s a quality challenge for those of us who live in Southern California.

Transition To Compliance

It’s been super cloudy and I’ve been telling everybody I want my money back. I don’t want to pay property tax for sunshine when we’re socked in, but we’re not here to talk about the weather. Most of my guests are either in-house or outside counsel. You’re a lawyer by training. We’re not going to do your career journey, but I know you did start at a law firm and eventually went to in-house roles. I want to talk a little bit about your transition from an in-house legal to the compliance ethics space. Tell me how that happened and how you got comfortable with that move.

There was not a specific official transfer. I took my first in-house job as a general counsel in the talent management world. I first landed in compliance at Coda Automotive, which was the electric car startup company. There, I had a corporate governance and corporate affairs role that flexed into compliance as well. That meant a lot of things. That meant compliance with SEC requirements as we were exploring IPO and becoming a new company or a public company.

It also included technical compliance, which in the automotive space is very different from anything I’ve done in the future. One of the confusing things about the term compliance is it can mean lots of different things. It can mean very technical compliance. It can mean broad cultural compliance and it’s very different from healthcare to banking to an industry like mine.

I fell into that work and enjoyed it. I handled employment matters. I handled a bunch of technical and then more broad topics. When I shifted over to Activision, I went in as the Director of Corporate Governance and Compliance. I had a very much board reporting and audit reporting governance role as well as compliance, which then was part of my job and part of my boss’s job, and that was it. It then evolved over time.

At one point, I was the Chief Risk Officer handling risk and insurance as well as compliance. Over the last several years, with our journey towards real more cultural workplace challenges, my team expanded significantly and it became separate from the legal department. When I came to Activision, as with previous roles, I was part of the legal department and very much functioned as a lawyer. Although now, my leadership team is 3 lawyers and 2 non-lawyers.

Compliance does have non-lawyers and lawyers and that varies by company. In some places, even when I started, it was very much a part of the legal department. Now we are a separate function, though on the heels of a large acquisition that all changed. I think about 50% of companies have compliance departments that are part of legal, and they function more like lawyers. There’s been a push away from that to have separation for a host of reasons.

I want to delve into that. Compliance reports to me currently in my company. When I was at the university, we were partnered, but they were separate. Since you’ve lived both ways, in your experience as a compliance officer, what was it like working under the legal function and now when you’re separated?

It’s a great question, and it’s a very hot topic in the compliance space because there are lots of very strong opinions about what the right way is and I think it’s moved. It might even be more than 50% separate now. I can say a lot of what makes the difference is the type of person who’s leading. It can work quite well within a legal department if you have the right lens of a lawyer leading the team. I think it can be difficult to hold the compliance perspective versus the legal perspective. The legal lens generally is to mitigate liability.

The ethics and compliance lens is more focused on what is the right thing for the employee base and for the situation. It’s a little bit different than risk mitigation. Most of the time, those things are aligned quite nicely. Some of the time, they’re not, and that’s where I think it becomes challenging not to have separation or to not have two separate votes, but the right person with the right mindset can hold space for both of those things.

The Legal Department | Jen Brewer | Ethics and Compliance
Ethics and Compliance: The ethics and compliance lens is more focused on what is the right thing for the employee base and the particular situation they are facing. It is a little bit different than risk mitigation.


Right Decision Maker

When you do have either under a legal vertical or separate, in your view, who is the right decision maker when you have those pain points where there’s a risk decision, but there is a “right” thing to do from an ethical or moral standpoint?

This is where the reporting is critical. If it’s within the legal department, the chief legal officer is the decision maker.

I would disagree, by the way, because I am in the CLO, and I think if it’s something that’s big enough where there’s going to be friction, I will take that up.

That’s the best practice. I don’t know that everybody does that. What we do is something similar. We have a review panel, and there will usually be alignment. If I meet with the Chief Legal Officer, the Chief People Officer, and the Chief Administrative Officer, more times than not, we will land at the same place. However, there’s this review panel process built-in so that if there is a lack of alignment, it goes up a level until the acquisition is reported to the audit committee chair and has internal reporting to the CEO.

That was a helpful balance because you can look at it from other perspectives. You can incorporate all these views. A better decision ends up getting made. Also, I think it’s a best practice to have reporting of some kind from the Chief Compliance Officer directly to whoever is leading the compliance oversight on the board.

It gives you that emergency break or that emergency off-ramp if things get tight. You don’t want to go there, but you know, you have it.

One of the most important things for Chief Ethics and Compliance officers, in general, is to establish and build relationships with other executives and the board so there can be a partnership. Also, there isn’t this black-and-white thinking. I think that can be a pitfall in the compliance space that there’s one right answer there. There isn’t and reasonable people can disagree. We want to be thoughtful about it but being considered a partner and valued as someone who will speak up and say the truth but also is reasonable and pragmatic.

The Legal Department | Jen Brewer | Ethics and Compliance
Ethics and Compliance: Chief ethics and compliance officers must establish and build relationships with other executives to create partnerships that do not depend on black-and-white thinking.


It’s because something that can happen as the more of a partner, a compliance function is, the more ability to influence, and usually the higher level up, you’ll see them because they’re a trusted partner. I think that having the separation can be helpful, especially when there might be less of a tendency to level up a decision, which is a close call. I think there can be a lot of benefits to coming to the table. What’s the right thing? I disagree with the chief legal officer. We have an upward audit chairperson because the close calls usually matter the most.

Advice For CLO And GC

What would you want the CLO or the GC to know? As the chief ethics and compliance officer, what would you want them to know about working with people in your profession or your role?

My advice for a CLO or, frankly, any in-house lawyer and I say this as an in-house lawyer. I think for lawyers, we can be very confident in our viewpoint and sometimes even unintentionally a little bit dismissive of other partners. I think that can often be HR partners. I think the same type of thing can happen with any other function and that’s something I’ve worked on checking that I know best.

Realizing it’s a totally different perspective and the more you can listen and lean in a little bit, it takes a little bit of time to pay attention, listen, and understand that it is truly a different lens. It’s because I think from a straight legal perspective, there’s like, “We can either do this or we can’t do this.” There sometimes isn’t as much time for what’s the right thing to do here. What’s the best way to handle it? How can we be more thoughtful about how this might land?

We make the decision and communicate the decision. Do we communicate it to employees? Do we communicate it to all? The thoughts about all those little things can make quite a difference in how something lands and I think coming to the table realizing that all these different partners have a different type of experience and it may not fit exactly into the way we think about things, but it is valuable.

That is a lesson I had to learn over time, to bring patience, to bring understanding, and to be willing to listen to a leader who’s coming at it from a completely different perspective. It’s very on the softer side, but I think it makes all the difference because I think it doesn’t work amongst different functions when there’s that feeling that there isn’t a lot of listening or partnership. There isn’t a willingness to think about things thoughtfully and just jump to one place.

I think that advice applies really to anybody in a corporate environment. Other people have opinions and things to say. I don’t know if you feel this way in the compliance and ethics space, but I feel a lot of pressure to get things done in the legal space. To move forward, we need to make this decision and go. That pressure or that feeling of urgency, I think you can sometimes short-shift the listening.

I totally agree, and it’s the same. There isn’t time for this. But I will tell you, speaking of listening, that is the single most important thing we can do. We’ve been on the heels of what I’d call a culture repair moment and the most important part of that is listening. Whether you’re in an investigation or you’re receiving feedback, it’s listening to employees. I think that muscle has gotten harder and harder for the entire world. Things go so quickly. There is no off time anymore. There is no, “It’s quiet time.”

Listening is the single most important thing we can do when we are on the heels of a culture repair moment. Share on X

It goes and goes. People respond. I would argue that people respond far too quickly on social media, email, and all these things. That that speed is 100%. There are a lot of I think within a company, “That’s not mine. That’s this person’s. I don’t do that. We just make the decision,” and it is difficult to have the time to discuss things that matter and not everything matters, but it does matter. It’s knowing how to prioritize. For compliance or legal folks, it’s picking the hills that matter. We’re at a time where we need to stop and think about what we’re doing here and have a conversation, get on the same page, and build a relationship.

Cultural Reboot

You mentioned having a cultural reboot. I had one in 2018 that I would say was a culture crisis that we experienced when I was at the university. That was the catalyst for me to spend some time focusing on developing my listening skills. I don’t know if you want to talk at all about it. I have read books. I listen to podcasts. I work with my coach. I realized and recognized that I was doing this thing.

I don’t know if it’s the legal training, but I’m just going to say it was a Stacy thing where I was doing what they call already listening. I’m watching your mouth move, but I already know what I’m going to say next, so let’s just fast forward with what Jen’s telling me, and I’m going to wait until it’s my turn. I’m going to pause and then it’s my turn to answer.

I think that is a lawyer thing. It’s not specific. I think it’s the training and a little bit of that. “I know what the answer is. I know where we’re going. I’m already planning my response.” I entirely agree with you. A cultural reboot is a great term to describe. When you’re faced with those moments and those times, you have to be willing to stop in your tracks when there’s no time to stop.

There’s constant time pressure but you have to be able to stop, take a step back, and look at what matters and what you’re talking about. There were so many things that came up for us in the early days of that cultural reboot where there was no good answer. There was no answer that would give anybody comfort, whether employee or not and there had to be a lot of listening.

Being able to listen truly is one of the critical skills of an investigator. I think that’s evolved over time as well. You have to build rapport, be present, and listen to someone’s story or care about someone’s story. If you don’t care, it is very apparent that you’re not listening. Also, I would say think outside the box. We had to be creative, think outside the box, and be willing to be uncomfortable. When you are going through a time like that, it is not comfortable. It is not fun. It is also an incredible opportunity for change because people will be willing to spend time talking about things that they weren’t previously willing to talk about.

Being creative, thinking outside the box, and the willingness to be uncomfortable are incredible opportunities for change. Share on X

It’s an incredible opportunity to combine really listening and taking the opportunity to leverage the attention, the focus, and oftentimes the resources. In our case, the resources have an impact. I think as stressful as those moments are, I think they’re incredible learning moments. I learned more walking through those several years than at any other point in my career.

I want to give some context for what we’re talking about here. In many episodes, we talked about the 2018 gravitational shift or the tectonic shift for me due to a big sex abuse scandal. In 2021, there was some public inquiry and regulatory activity around the #MeToo adjacent issue at Activision. I don’t know if you want to say more about that, but just to give a little context for all this great personal growth we both got to experience.

I will say it’s been a journey. The one other thing I would say is compliance ethics and compliance, you move topics based on where the risk is. Third-party risk might be at the top of one’s mind one day. In fact, in 2021, that was something that was at the top of my mind, and it very quickly became on the back burner compared to the other issues that we were dealing with. Over time, there has been a journey in the last few years where topics that used to be HR topics became board-related topics. #MeToo is very much in that. I think issues of harassment and discrimination. Those used to be described as HR topics.

It’s because we have an HR issue.

Now, those are workplace culture issues. I think that shift was happening. I added one investigator to my role on my team in 2018. In 2021, there was one explosive public inquiry, but there were a number of others with CRD SEC. There was a ton of media press.

I learned what the alternate facts are. That was my experience. It’s unfortunate, but I have a little bit more of a jaundiced eye media-wise now.

Even my kids are like, “I saw this.” I was like, “Just because you saw it doesn’t mean.” but it was a tough moment. It was in the summer of 2021. It’s one of those, “I remember where I was or what I was doing.” My husband had COVID at the time and my kids were little. It was a very emotional thing to happen to every single employee at the company, and it was external because it was in the land of all kinds of media and social media posts.

I think that was a huge shift and that would carry down the story of how the stock price dropped. The bid from Microsoft came in. It set the stage for a lot of things to happen. I think people could spend days and weeks talking about all the things that have led to these various moments, but when you’re in the middle of that, there’s this constant pressure of, “How are we responding? What are we doing?”

Make it go away.

It needs a thought. It takes time. Also, human beings and lawyers included, it’s an emotionally reactive period of time.

I was so shocked at how much our experience affected our outside counsel. I noticed the dynamics. We had a very large outside legal team and our insurance brokers and the friction between them or the reactions with them. I think you and I have talked before about this idea of professional trauma, which is something I’m thinking about for some other conversations, but it’s interesting. I think that from a distance, it looks like, “There’s a crisis. There’s a scandal. It’s a shit show over there,” but as you’re saying, there are people involved at every step of the process, and everybody needs TLC leading through it.

I think trauma is the right word. I would say that for every employee at this company, as well as for outside folks, that is 100% true. I had the same experience of how people were affected by it. There’s time to study that psychologically. I would be interested. It’s fascinating but incredibly painful and uncomfortable to go through and people are just doing the best they can. I think there can be incredible growth that happens in those times and everybody does need a little bit of extra care. I think care can be on the shortlist because of how much stress, how many hours, or how much time is being spent trying to work through issues that don’t have an immediate solution.

Heroes Program

You can’t make it better. I know your leadership, in particular, helped reboot, but you led and created an innovative program out of that. Do you want to talk about the Way2Play Heroes program?

The Way2Play Heroes program started in 2018, and it was supported by the very senior-most folks in the company. However, if you look at the progression, there was a lot of interesting stuff going on within the ethics and compliance function. We had a good operation. It was small and leanly staffed with 2 or 3 people. In 2018, the #MeToo Movement was very much happening and there was just this sense.

We had a large company around the globe, and we didn’t have enough people to represent all of those places. One of the things I believe in compliance is there can be a lot of one-way communications like, “Do this, follow these rules, take this training, don’t do this, or submit this if you want to do this, but it’s this one-way communication.” However, for something to land and impact employees, behavior and how they do their jobs, it has to be a conversation. It has to be two-way.

As a lawyer and with legal training, how did you know that? How did you have that insight?

One of the things that we dealt with at Activision, in particular, there are multiple business units. Those are completely different companies. You have an Activision culture, you have a Blizzard culture, you have the King culture, and then you have cultures within those companies that make different games that are entirely different. You couldn’t roll something out and have it work for everybody.

A lot of that I learned from watching how difficult it was to get things done. Policies never work if you just roll them out and say, “Do this.” They have to reflect and mean something to the employees. The bigger you get, the harder it gets to incorporate that, but also, the more established and open your culture is of compliance and of talking about these things, the easier it gets to do.

The Legal Department | Jen Brewer | Ethics and Compliance
Ethics and Compliance: Company policies never work if you just roll them out. They have to reflect and mean something to your employees.


I had navigated a lot of the challenges of people who aren’t going to pay attention, even read a policy. They don’t want to. They don’t care, but if they get a voice in that and understand that this is being created to help us be more successful as a company, they have a different buy-in to that. That was one of the clear learnings I learned just being here in a corporate function with all these business units who wanted nothing to do with corporate function.

It was very practical to learn, and we had a lot of conversations about things that were just starting to bubble. Even getting the Heroes program off the ground was incredibly challenging. Now, 150 employees from around the globe have other jobs they don’t have, but these are people who are interested. We call them cultural guardians. They’re interested in doing the right thing. They’re interested in being a part of a positive workplace culture and they care.

They’re the people who like to know what the guidelines are and want there to be clarity. They’re the people who are already trusted by leaders, peers, and more junior members. They’re the people who are already on a team, and someone’s going to them for their advice because they know they’re a trusted resource. What we did is in 2018, we started with about 75 Heroes program.

How many employees were at the company at that point?

It was somewhere between approximately 12,000 or 13,000 employees or probably maybe 10,000 employees in 2018, and then it is somewhere between 10 and 15 now. It had 75 employees, and we had to fight to get people to buy in. This is going to be all of their time. You’re going to create a team of spies. This isn’t going to work. There were so many different pushbacks, and we had to fight them with each business unit and group.

This is where my advice for relationship-building at all times. If you don’t have deep, trusted, and real relationships, it takes time to build those relationships. It is incredibly hard to get things done when it matters. I leveraged the trusted relationships I had. I also had the support of the CEO and the senior-most leadership to get it done, but that wasn’t enough with how spread it was. I needed the buy-in for everybody. We finally got that. We kicked it off in 2018. It was beyond our wildest expectations. In that first session in 2018, we workshopped a policy that was about to roll out. It was the relationships at work policy.

You have 75 people who have other jobs who get together to work on a policy together.

They came to a two-and-a-half day training in Barcelona. There are things probably once a quarter and then there’s a lot more infrastructure and support around materials to help them. It was going to be less than 5% of their time, but they had to get trained. We had to provide training on what it means to be a Way2Play Hero because, done wrong, you can have people making all sorts of messes. We needed to do it right and give them the support and training.

We did not know in 2018 how critical they would become later and how central their role would be to this movement. We got them together in one session. We workshopped a policy. With the feedback and ideas I got, I thought to myself, “Never in a million years would lawyers in a room come up with these ideas.” We ended up changing not only the policy itself, but we changed the portal through which people would disclose things based on how they were such thoughtful things.

That was when I started to see that this group was going to change the way we do things. They are going to have thoughts and ideas that would never have crossed our minds. That is what has continued to happen. It’s been the coolest thing of my career by a long shot. We had a Way2Play Hero Summit in Barcelona and it’s as magical now as it was then. Only it’s way more people and infrastructure.

Do the heroes feel that way?

The heroes still listen to their quotes and testimonials. There are people who said they stayed at the company because they were part of the Heroes program. It’s been a pretty impactful, empowering, and incredible experience. We didn’t expect that 2021 was coming when we’d have this moment, and there was a period where there was no trust in leadership.

People didn’t know what to believe. They didn’t trust HR partners. They didn’t trust leaders. They didn’t trust legal but they did trust Way2Play Heroes. Those heroes were trusted resources, and they did a ton of listening. We then started providing more support for them around how to have these conversations. We have a person on my team who’s incredible. Her background is incredible, and she does trauma-informed practice training.

It’s not funny, but you wouldn’t think that you would need those skills to bring into the workplace. In healthcare, we talk about it all the time in terms of trauma-informed care delivery but not so much in how we deal with each other.

It’s critical for these employees who have lived through years and years and everybody brings their own personal experience. I remember in myself in 2018 when the #MeToo Movement happened. I was remembering things from way back in my early career. It brings up a lot of historical stuff, too, and how we treat employees and every single interaction, every single person on my team is approachable and trusted.

I want any employee to be able to walk into any of their offices, call any of them, and be treated with care and listening. That’s our investigation process. We have someone who’s an employee investigations navigator. Her entire role is to provide support to employees on all sides who are going through things. That care you’ve talked about became the best thing that we could do.

I think that’s so innovative. When we talked before, I remember because I feel like what happened in my former life was this lack of trust because there was a perception that things were swept under the rug, which I disagree with, but we need to get more investigators. We need a bigger investigatory department to go out and find the truth, so to speak.

It was not accompanied by that care and feeding approach. I think that it’s important that having been interviewed myself at times and having interviewed other people, this experience can be traumatizing in and of itself. Many have gone through that and then see, “When I’m giving someone an Upjohn warning, that’s freaky.

It is fundamentally scary, even for lawyers, to receive an Upjohn warning. You know what it is. It’s a traumatizing experience for many. I think that part of the world has shifted a lot. We say on my team that our mission is to always be people-first. Compliance doesn’t matter. Compliance is important. That’s our business, but when you approach it from people first, human beings first, it changes the lens through which you do everything and that does move the needle on the work that you’re trying to do. People think also that if we spend all this time taking everybody’s feedback, we’ll never get anything done. There is truth to that. It’s a balance between, and that’s where the heroes became critical. We had this pocket that was a microcosm of the whole company where we could collect all of their feedback.

When you take a people-first approach to managing your team, it can change the lens through which you do everything and move the needle on the work you are trying to do. Share on X

Did they self-select and was there anything in infrastructure under them so they could get feedback from their departments or whatever? How did that work from an infrastructure standpoint?

They were nominated and vetted because you do need to have the right people in those roles. Also, there’s a lot of feedback throughout and in different ways. The infrastructure has grown substantially over time. At first, it was me and two other people. I was like, “We’ll try to get you some stuff when we can,” but there’s a lot of training provided and a lot of feedback because as much as understanding what the role of a hero is, it’s also important to understand what it isn’t.

A lot of the people who want to join the program are people who want to make a difference in the world. They want to solve problems and help people, but they are champions of the process. They’re not in a position where they can solve people’s problems. They can’t save everybody and being neutral is also important. They can’t just be advocates for the person who comes from them. They have to champion this process, a neutral objective review provided by a separate group. As a hero, I can’t make sure what happens. I think a lot of training, feedback, and support goes into the entire program.


You talked about the opportunity in crisis, and I believe that as well. Maybe that’s just a survival mechanism. “I’m going through this hard time, but there’s a silver lining.” You talked about people first and listening, but there’s another area we talked about before, which I believe is core to a healthy, ethical culture, and that’s transparency. I know you’ve been a champion for that, having won the Corporate Governance Professional of the Year Award. Can you talk about how transparency played a role in that process and how you’ve used it in your role to improve the culture?

I think transparency is one of the single biggest challenges that we face. As lawyers, compliance folks, or executives of any function companies, how do we get that right? I think there is an ask across the board from shareholders, stakeholders, and employees. We want to hear how we get that right with transparency. The world has moved in this regard.

One thing we’ve done from a process standpoint is any employee who reports something or goes through a process of an investigation, whether they are the person raising a concern, whether they’re the person about whom a concern has been raised will be closed out with and they will know what the determination was an outcome. Not all companies can do this, but for many years there was a black box like I erased something or what happened? I have no idea.

Also, there are privacy things that protections have to be navigated, but there’s a strong commitment within every matter that we don’t even consider a matter closed until the key parties have been closed out with, have had an opportunity to hear the outcome, and understand. People said, “You can’t explain everything.” No, you can’t, but what we found is that people understand, “We looked into this and we found out, yes, this did happen,” or, “We found out, no. The evidence didn’t support a finding that it happened.”

Just that conversation gives people an incredible amount of closure. That part has been huge. I think there’s also transparency in reporting. That part changed dramatically for us. The level of detail, metrics, trends, and types of things. We also had a transparency report, which provided data about investigations for the first time. I think there are companies that are starting to provide that type of data. It’s tricky to do it right because everything is a moment in time. There are so many different factors and so many different caveats that you can’t well include.

You have the legal lens. I know there’s a lawyer somewhere still. You think about having data around whatever the complaints are and the number of substantiated complaints. You worry about the plaintiff’s bar and using that as a very fertile recruiting ground.

One hundred percent and by the way, I very much identify. I am a lawyer. I’ve come a long way. I started as an M&A lawyer in my role now, but I will always think with that brain. I think that was a thing that was hard. Listening and sharing transparently is very tricky to do right. Even though it’s what people want, we can’t always meet that because there are also other things to protect.

There are individual people’s privacy and information is always contextual, and you cannot understand everything. I think it’s tricky to get it right. I think it became necessary when people said, “This is awful. This is so widespread,” but the facts say something different. That’s where I think companies are trying to find a way to do it. It is not easy.

I would say lawyers and compliance folks are aligned on this front. It is tough to get this right. Where I support transparency is when we can let individuals who are impacted know a little bit about whether the allegation or the concern they shared was found to be substantiated or not substantiated because that part used to never be communicated. I think it goes a long way to building trust in the process and companies are all over the map in terms of how they deal with these things.

Trusted Human Relationships

This is a journey. This is new. By using #MeToo as the triggering event that’s gotten everybody to look at things differently, we’re still very early in that journey to a new way of dealing with things. Let’s be easy on ourselves here. We don’t need to have figured it all out. If you had a last piece of advice for a general counsel and other in-house lawyers working with compliance, what would that be?

I don’t know if it’s specific to working with the compliance legal, but again, I lean on building trusted human relationships with people and coming to the table with the view that there’s something valuable that can be learned. I think that sometimes in the separation of departments, there could be a little bit of us versus them. That is counterproductive. I think we’re all on the same page. If we can share and talk about the various different concerns, we get to the right place. That’s been my experience.

The Legal Department | Jen Brewer | Ethics and Compliance
Ethics and Compliance: Separation of legal departments usually leads to a bit of competition. This is counterproductive, and everyone must realize that everyone is on the same page.


There are very few times we don’t disagree, and I think some of those engaging debates about the right way or what the right thing to do here is worth having. It’s worth the time and you can do it if you have trust in relationships. I know we can hash it out. We can see things differently. We can land in the right place. It comes down to that principle of psychological safety, which is talked about a lot within teams, but I think effective leaders are able to build those same groups where they know that they can have different views, and then they’re going to land on the right one.

If people are heard, the fact that you came out a different way doesn’t hurt so much.

Ninety-nine percent of what we have found with my team’s work in terms of reviewing matters is just to feel heard. That is a human-shared thing to be heard. If you listen, even if I make a different decision, it’s going to have a positive impact on our long-term work together and relationship.

Pump-Up Song

I close all conversations with the same last question. Thinking back to that hard time in my career, I realized that I need music to get pumped up and get through hard times. Also, be fun and be excited about things. Jen, what is your pump-up song?

I love this question. I think it’s so great. My daughter would know how to answer this question, but it’s Sia’s Unstoppable. I needed that song. There were times when I was like, “You can do this.” I agree. Music is important.

I’ll tell you more about my pump-up journey off mic, but thanks so much.


Important Links


About Jennifer Brewer

The Legal Department | Jen Brewer | Ethics and ComplianceJen Brewer is a versatile and dynamic people leader whose superpower is building high-trust, authentic relationships amid rapidly changing business environments. After 10 years of successful leadership roles at Activision Blizzard, she was appointed as Chief Ethics & Compliance Officer, responsible for Activision Blizzard’s global Ethics & Compliance program, dedicated to fostering an ethical, speak up culture. She leads a team of more than 30 lawyers and compliance professionals, an integrated investigations unit, companywide ethics and compliance training, policy development and enforcement, and data analytics. Jen is passionate about the meaningful work she and her team lead and is honored to mentor and develop her talented colleagues.

A native of Portland, Oregon, Jen’s 20+ legal career began as a corporate associate at Skadden, Arps in Los Angeles, focusing on Mergers & Acquisitions. From Skadden, Jen went in-house to hold various executive-level legal roles. She is a fierce advocate for speaking up and is proud to have pioneered the Way2Play Heroes program, Activision Blizzard’s first global ethics ambassador program across all of its businesses, now with more than 140 employees around the world.

Share this blog: