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Founder & President
Axiom Compliance & Ethics Solutions
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Jim Nortz
About / Bio
Nationally Recognized Expert & Thought Leader

Jim Nortz is an attorney and a nationally recognized expert and thought leader in the field of business ethics and compliance with over a decade of experience in the field of healthcare compliance serving multinational pharmaceutical and medical device corporations.

Jim spent the first 17 years of his career as a litigator and corporate counsel before becoming Crompton Corporation’s first Vice President, Business Ethics and Compliance in 2003.

Since then, Jim has served as a compliance officer at Crompton and for five other multinational corporations, the most recent of which was as Chief Compliance Officer at Carestream Health. Jim has extensive experience in implementing world-class compliance and ethics programs sufficiently robust to withstand US Department of Justice scrutiny.

Jim is a frequent guest lecturer at the University of Rochester’s Simon School of Business, RIT’s Saunders School of Business, St. John Fisher College, Nazareth College and other law schools and universities around the country.

Jim writes the monthly business ethics columns for the Association of Corporate Counsel Docket magazine and the Rochester Business Journal.

Jim is a National Association of Corporate Directors Fellow, member of the International Association of Independent Corporate Monitors and serves on the Board of Directors of the Rochester Chapter of Conscious Capitalism as the Board’s Secretary and Chair of the Governance and Nomination Committee. Previously, Jim served on the Board of Directors for the Ethics and Compliance Officers Association (“ECOA”) and the Board of the Rochester Area Business Ethics Foundation.
Corporate Monitoring Exp

For over 25 years as house counsel and a compliance and ethics professional, Jim Nortz has successfully built and implemented compliance and ethics programs for six multi-national corporations sufficiently robust to withstand DOJ scrutiny in difficult circumstances in which several of these companies had voluntarily disclosed instances of potential criminal conduct. As a monitor, I'll be able to help firms I am assigned to build and sustain all elements of a world-class compliance and ethics program that will successfully detect and prevent misconduct.

Professional Experience


Axiom Compliance & Ethics Solutions LLC, Fairport, New York

Compliance & Ethics Consultant and Educator                                                                     2018 – Present

Offer compliance and ethics consulting services to corporate clients to help them thrive by building sound internal controls and a strong ethical culture. Recently completed projects for several multi-national clients include:

  • Anti-Kickback Statute legal analysis of a client’s proposed marketing plan.
  • Development and implementation of a global sunshine reporting program.
  • Development and implementation of a global due diligence program for sales intermediaries.
  • Revisions of several LRN on-line training courses on the US Anti-kickback Statute and industry ethics standards for the bio-medical industry.

Carestream Health                                                                                                               

Chief Compliance Officer, Rochester, New York                                                                     2015 – 2018

Key achievements:

  • Implemented a comprehensive, global compliance and ethics program that included an investigation manual, investigator training program and 5 regional sales and marketing codes to ensure compliance with anticorruption laws and industry ethics standards.
  • Led initiatives to enhance the company’s global third-party due diligence and life-cycle management for sales intermediaries.
  • Led 6 complex, multi-national investigations into alleged violations of the US Foreign Corrupt Practices Act (“FCPA”) by Carestream employees and dealers in India, Mexico and China.
  • Saved the company over $10 million in fines and corporate integrity agreement costs by persuading the US Department of Justice to decline prosecution for FCPA violations based on the thoroughness of the investigation and the strength of the Company’s global compliance and ethics program.

Sutherland Global Services

Corporate Compliance Director, Victor, New York                                                                 2014 – 2015

Key achievements:

  • Developed and implemented Sutherland Global Services’ enterprise-wide Compliance and Ethics Program designed to detect and prevent criminal conduct that included a world-class 24/7 helpline and case management system, an investigation manual and investigator training.
  • Identified control system weaknesses and recommended corrective actions in the Company’s highly regulated mortgage services business.

Built on Ethics Advisory Services

Compliance and Ethics Consultant and Educator, Fairport, New York                                     2013 - 2014

Provided training and consulting services to assist organizations in building sound internal controls and strong ethical cultures.


Bausch & Lomb

Compliance Director, Rochester, New York                                                                             2007 – 2013

Key Achievements:

  • Led the development and implementation of Bausch & Lomb’s global Compliance and Ethics Program that included over 40 country-specific sales and marketing codes of conduct.
  • Avoided a corporate integrity agreement following the company’s purchase of ISTA Pharmaceuticals based on the strength of the compliance and ethics program.
  • Implemented a global FCPA compliance system and training program.
  • Delivered live training in multiple locations around the globe to over 2,000 employees regarding anti-corruption/anti-kickback compliance, anti-trust compliance, ethical leadership, ethical decision-making, competitive intelligence gathering, giving voice to values and trust fundamentals.


Ethics Resource Center

Senior Advisor, Arlington, Virginia                                                                                          2006 – 2007

Assisted the ERC with a global anti-corruption project conducted in coordination with the World Bank.


Kraton Polymers, LLC – a Texas Pacific Group Company

Chief Compliance Officer &

Global Director of Safety, Health and Environmental Affairs, Houston, Texas                        20052006

Key achievements:

  • Chaired the Corporate Compliance Committee comprising the Kraton senior management team and implemented a comprehensive global compliance and ethics program.
  • Successfully managed the Company’s safety risks and achieved an OSHA recordable injury rate of less than one.
  • Drafted and assisted in the implementation of the corporation’s disclosure controls procedures to ensure full compliance with Securities and Exchange Commission regulations.

Adecco Management & Consulting SA

Group Vice President, Business Ethics & Compliance, Woodcliff Lake, New Jersey                2004 – 2005

Key achievements:

  • Drafted and published Adecco’s code of business conduct, upgraded 24/7 helpline and associated case management system, implemented a new on-line training system, drafted and published investigation and reporting handbook and implemented a global Web-based fraud reporting system.
  • Led an investigation culminating in a report to the FBI and the conviction of a senior executive for embezzling over $1,000,000.

Crompton Corporation

Vice President, Business Ethics & Compliance, Middlebury, Connecticut                                2003 - 2004

Key achievements:

  • Developed and implemented an effective global business ethics and compliance program in the wake of a significant anti-trust scandal involving Crompton employees.
  • Led the Company’s first comprehensive systems evaluation of its key compliance management systems.
  • Incorporated ethical considerations into all aspects of employment practices – hiring, performance evaluations, training, promotions, bonus programs and disciplinary actions.


Crompton Corporation

Senior Safety, Health, Environmental & Litigation Counsel, Greenwich, Connecticut             1994 - 2003

Advised Crompton Board of Directors, senior management and plant managers worldwide on legal issues related to safety, health, environmental and regulatory affairs affecting global operations. Managed over 37,000 lawsuits and 125 law firms.

US Army Judge Advocate General’s Corps

Litigation Attorney, US Army Environmental Law Division, Arlington, Virginia                    1990 – 1994

Represented the US Army in environmental litigation, nationwide.


Government Appellate Counsel, Falls Church, Virginia                                                           1990 – 1990

Wrote appellate briefs in cases before the United States Court of Military Appeals and the Army Court of Military Review involving a broad range of constitutional, criminal law and evidentiary issues.

Criminal Defense Counsel, Army Trial Defense Service, Germany                                          1987 – 1990

Tried over 90 cases defending clients in Courts Martial accused of offenses ranging from misdemeanors to capital crimes, including murder, rape, arson, robbery, drug distribution and fraud winning acquittals for 9 clients.


US Army Judge Advocate Officer Basic Course, The Judge Advocate General’s School, Charlottesville, VA

Juris Doctor, Dickinson School of Law, Carlisle, PA

Bachelor of Science, Mechanical Engineering, Rochester Institute of Technology, Rochester, NY

Professional Memberships
  • Author of the monthly business ethics column since 2004 for the ACC Docket – The Journal of the Association of Corporate Counsel.
  • Author of the monthly business ethics column in the Rochester Business Journal since 2008.
  • Member of the Ethics & Compliance Initiative and the National Association of Corporate Directors.
  • Member of the Ethics & Compliance Initiative’s High Quality Program Assessment and Preventing Corruption Working Groups.
  • Frequent lecturer at colleges, business schools and conferences nation-wide.
  • Lead facilitator of Nazareth College’s Interdisciplinary Institute for Professional Ethics dialogues with academic and business professionals regarding the root causes of weak ethical cultures in corporations.
  • Steering Committee Member, Rochester Chapter of Conscious Capitalism.
  • Former member of the Ethics and Compliance Officers Association (“ECOA”) Board of Directors.
  • Former member of the Rochester Area Business Ethics Foundation Board of Directors.
  • Former steering committee member of the Open Compliance and Ethics Group.
  • Founder and former chair of the Westchester/Fairfield Association of Corporate Counsel Business Ethics Roundtable.


  • Pennsylvania
  • Connecticut
  • New York
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