"Compliances need to be at the forefront now, as they have become a risk management tool, and non-compliance has severe consequences.”
Having worked across various sectors, what shifts have you observed in how compliance functions are expected to enable innovation?
The compliance function in an organization has seen a rapid shift in the past few years. There was a time when no one had heard of a separate compliance function, particularly in the Asian world. When I started my career, I recall that the number of compliances was not too much and there were hardly any corporate compliances, all the focus was on labor and factory / industry compliances only , which were mainly handled by the HR and Industrial Relations person in the plant itself. No compliance reporting was done anywhere within the organization. It was only the forms and returns with authorities which used to be submitted manually , and just taking an acknowledgement /stamp from the appropriate authority was enough
Since there were no online records, even with the authorities if any compliance was done, the acknowledgement/stamp was the only evidence of compliance. Few other compliances under the Companies Act were also crucial, but yet again , challenging to manage, and were done in a routine manner by either company Secretaries or CFOs. There was no concept of CFOs at the time, and they were referred to as Head of Finance or Head of Accounts, or other similar titles. Compliances were never seen as a challenging task. However, over the past 10-15 years, the entire scenario has changed, and we have seen a complete shift in the way compliances are managed. The primary reason was the increase in compliances and the complications attached thereto. Then there was the start of a separate compliance function.
Compliances need to be at the forefront now, as they have become a risk management tool, and non-compliance has severe consequences. Organizations have realized the risks involved in non-compliance, whether it is corporate compliance, SEBI or Capital market compliance, Factories, EHS, or ESG compliance, and other industry specific compliance. The compliance itself has become an altogether separate function. It’s not easy to manage compliance today manually.
The effective mechanisms of compliance are also now mandatory under various regulations, including the Companies Act, SEBI, and other industry-specific compliance requirements
The Board and its committees have been mandated to review the compliances of an organization and it’s a big responsibility on the corporate boards also today to ensure proper compliance and ensure an effective mechanism for compliance, failing which the Board and KMPs may also suffer consequences, which again can be described a big shift in the approach.
The need for a compliance tool or software is an essential part of a compliance function today; only then a correct picture can be reported.
How has your experience in investigations and risk management shaped your approach to governance in industrial enterprises?
I handled numerous investigations and other similar assignments , including brand protections, Anti-bribery, due diligences, throughout my long career tenure. The lesson we learned from all these is that people try to justify their wrong approach, and therefore, the organizations need to handle this in a different manner.
While people management and transparency are one thing that can bring governance and reduce economic crimes and wrongs, making employees feel that the organization takes good care of them and adequate employees related polices are there and being implemented is also an essential part of Governance.
While Governance is about right processes and ethical practices, implementation in the right spirit and way is what is expected from organisations.
In the context of India’s data privacy regime, how should companies in manufacturing and FMCG rethink compliance?
The personal data of an individual needs to be secured; failing which creates a situation of mistrust and negligence.
Hence, yes ,there is essentially a need to rethink the entire approach to data privacy related compliance not only in letter but also in spirit. In today’s digital world with no boundaries, it is the moral and ethical duty of an organization to ensure that the personal data is protected. This will drive the success of the organization going forward.
Data privacy is crucial for the organization’ success and plays a vital role in my view.
What lessons from your time in risk and investigations remain relevant as cyber threats increasingly impact industrial operations?
Cyber threat is for real today. We are witnessing a large impact on the organisation as well as its stakeholders and this risk is highly important to address. Their awareness is the key to this. The organization also understand its duties as stakeholders and must abide by them.
The organisation needs to spend time on training and awareness sessions and ensure that the stakeholders not only understand the threat but also are believe that the organisation has minimised this risk.
About Sameet Gambhir:
Sameet Gambhir, FCS, LLB, is a seasoned legal, compliance, and risk management professional with over 35 years of distinguished experience across leading organisations like UFlex Limited, DCM Shriram, KPMG, Schneider Electric, and Hill & Associates. Currently serving as Sr. Vice President & Group Head – Legal at UFlex, he has also completed a Leadership Effectiveness Programme from IIM Bangalore.
Mr. Gambhir’s expertise spans corporate legal affairs, governance, ESG, IPR, cross-border transactions, regulatory compliance, M&A, risk management, data privacy, and labour laws. He has been repeatedly recognized as one of India’s top GCs, with accolades including Forbes India’s Top In-house Counsel (2021–24), Legal500’s GC Powerlist (2022–24), and LegalEra’s Distinguished Legal Minds. He has also received honours from ASSOCHAM, Business World Legal, UBS Forums, and LexTalk World.
He holds leadership roles in key national legal and corporate governance bodies, including PHDCCI, CII, ASSOCHAM, DMA, ICSI, BIS, and EODB (Ministry of Commerce & Industry). A respected academic voice, he regularly lectures at top institutions like IMT, IMI, LBSIM, and NDIM.
A pro-bono contributor and a keen golfer, Mr. Gambhir exemplifies thought leadership, integrity, and cross-sectoral excellence in corporate legal affairs.
