"Ethical leadership is tested when the cost is personal. If you can stand your ground then, you’ve truly led.”
You’ve led global compliance functions for over two decades, across high-stakes and cross-border environments. What does ethical leadership look like to you?
Ethical leadership is about having the courage to do the right thing, not just when it’s convenient, but when it’s costly or unpopular. It’s the ability to balance business imperatives with moral imperatives, ensuring that integrity is never compromised for expediency. For me, ethical leadership has meant standing by my values even under threat, from being physically attacked in my own office by a contractor trying to stop my labour trafficking report, to navigating situations where my work put me at personal risk. It’s about being transparent in decision-making, taking ownership when mistakes occur, and creating a culture where speaking up is not just safe, but expected.
Your efforts against labour trafficking led to the 2012 Executive Order under the Obama administration. What did it take to push that forward, and what impact did it have?
It took persistence, courage, and a willingness to face real danger. For seven years, I documented the exploitation of thousands of migrant workers in government contracting supply chains — often under surveillance and in prohibited zones. When I was banned from interviewing workers in their camps, I literally dug into the sand under barbed wire and crawled in at 2 a.m. to avoid security. I faced death threats, and once, a contractor entered my office and throttled me by the neck, warning me not to submit my report.
Despite gathering overwhelming evidence, my findings were ignored for almost a year — during which I lost several labourers who had bravely shared their stories with me. The turning point came when Senator Blumenthal, during a congressional committee hearing, publicly demanded accountability from the Combat Human Trafficking department: “This lady put her life on the line and investigated and made this report, and you didn’t have the decency to verify or reply to her email and calls? In a month you kick your boots, go to Baghdad or wherever it’s required, and give us the report findings.” That moment was a relief , not just for me, but for the memory of those workers. Ultimately, the evidence contributed to the Executive Order of September 20, 2012, which prohibited human trafficking, forced labour, and deceptive recruitment in U.S. government contracts. The impact was global, setting enforceable standards for ethical supply chains.
Before President Obama signed the Executive Order, there was a joint meeting where members of Congress and Republicans gathered in a large hall. I stood before over a hundred senior administrative officials and read my full report. The room fell silent. Many could not comprehend how such exploitation could exist — how men who should have been paid for their work were instead paying money to traffickers.
Mr. Cody, a secretary to the Army General seated on stage, looked at me and asked:
“These many men, for these many years, were denied their God-given rights… Why did no man speak up? Why is it a woman standing here today?”
His words struck me like a bolt. Until then, my thought had been, “Look what they are doing to people like us!” But that question has haunted me ever since. It made me realize that slavery is not only imposed from the outside — it can live within us. Especially for many Indians, our lack of self-respect and awareness of our nation’s greatness can lead us to surrender too easily to the idea of Western supremacy.
“I didn’t just investigate trafficking, I crawled under barbed wire at 2 a.m., faced threats, and kept going because the workers’ voices deserved to be heard.”
Given your extensive experience, how do you see the role of compliance leadership evolving in global maritime and logistics sectors amid tightening regulatory scrutiny?
Compliance leadership is moving from being a policing function to being a strategic enabler of trust and growth. In maritime and logistics, sectors that span multiple jurisdictions and cultures, leaders now need to be equally fluent in sanctions regimes, ESG frameworks, cyber risks, and local sensitivities. It’s no longer about reacting to violations; it’s about predicting risks before they surface. This requires courage of the kind I drew upon in my anti-trafficking work, entering prohibited zones, facing threats, because today’s compliance leader must be ready to navigate volatile, high-stakes environments with both strategic foresight and moral clarity.
“That Executive Order wasn’t just policy. It was justice for those who never made it home.”
What do you believe are the biggest operational challenges in conducting cross-border compliance investigations, and how can companies mitigate them?
The biggest challenges include differing legal systems, inconsistent access to information, language and cultural barriers, and the potential for local interference or retaliation. In high-risk jurisdictions, even gathering evidence can endanger whistleblowers and investigators. I have seen informants punished, deported, or worse. To mitigate this, companies must establish clear global investigation protocols, ensure local teams are trained in both legal and cultural nuances, and protect whistleblowers with robust confidentiality measures. Collaborating with credible local counsel and leveraging secure technology for evidence gathering is essential, not only to protect the case, but also the people behind it.
“When Senator Blumenthal called out officials for ignoring my report, it wasn’t just my relief, it was vindication for every life lost to silence.”
Maritime services are facing increasing ESG and sanctions compliance requirements. How should compliance leaders prepare their organizations for emerging risks?
The shift must be from reactive compliance to proactive risk intelligence. ESG and sanctions requirements need to be integrated into every operational process, from supplier onboarding to daily operations, rather than treated as afterthoughts. Just as I learned in trafficking investigations, preparation and foresight are key. We must train teams through scenario-based exercises so they can identify and respond to complex risks in real time. Collaboration between compliance, operations, and sustainability teams ensures that risk awareness is embedded throughout the business, not soiled in one department.
“Compliance is not a desk job. Sometimes it’s the front line, and the risks are real.
In the coming years, how do you envision inspiring and equipping the next generation of compliance leaders to combat exploitation in all its forms globally?
We need to go beyond technical training and instil courage, empathy, and resilience. Combating exploitation is not just about knowing the law, it’s about having the conviction to act when human dignity is at stake. I want young leaders to understand that compliance is not always a desk job; sometimes it means entering places you’ve been told to avoid or protecting people who are risking everything to tell the truth. By sharing real-world stories, from crawling under barbed wire at 2 a.m. to standing up in the face of political and corporate silence. I hope to show that the fight for integrity is as much about human grit as it is about legal frameworks.
“Teach them the law, yes, but also teach them courage, empathy, and the grit to stand alone if they must.”
About Sindhu P. Kavinamannil:
Sindhu P. Kavinamannil is an internationally recognized compliance leader with over 20 years of experience driving ethics, integrity, and risk management across high-stakes, cross-border environments. As Head of Global Compliance in the maritime sector, she has led transformative programs spanning sanctions, ESG, and anti-corruption, embedding ethics into the core of multinational operations.
Her defining work came in the fight against labour trafficking in government contracting supply chains. Over seven years, often under personal threat, she documented the exploitation of thousands of migrant workers. Her findings contributed to the September 20, 2012 Executive Order signed by President Obama, prohibiting human trafficking, forced labour, and deceptive recruitment in U.S. government contracts.
A recipient of a U.S. Hero Award nomination, Sindhu blends legal expertise with moral courage, mentoring the next generation of compliance leaders to see the profession not as a checklist, but as a calling to protect human dignity. Her vision continues through her leadership roles and her work with the Mudivili Foundation, promoting emotional intelligence and ethical leadership worldwide.
