How to Play Nice

Jennifer Brewer, Activision Blizzard’s VP, compliance & chief risk officer, is making compliance fun for game developers

Standing before a group of seventy-five Activision Blizzard global employees gathered for a training summit, Jennifer Brewer was taken aback by a phenomenon that is almost unheard of today, especially in the tech and gaming world in which she works. “Nobody was on their phone. Nobody had their computer open,” she recalls. “There were so many moments where I thought, ‘Is this really happening?’”

Brewer, vice president of compliance and chief risk officer, was prepared for the opposite experience, given that most trainings last two hours and this one was two and a half days. But this training was also a special event—the launch of the Way2Play Heroes. This group of ethics and compliance champions, nominated and selected from Activision Blizzard’s thousands of employees around the world, was slated to give feedback about compliance policies and programs to Brewer’s team and learn to provide on-the-ground training and communications to their local colleagues.

Jennifer Brewer, Vice President, Compliance and Chief Risk Officer, Activision Blizzard Courtesy of Activision Blizzard

The project took years to develop, and Brewer’s team had worked tirelessly on the launch. While most companies would rely on an outside consultant to develop and deliver the content, Brewer’s team did it primarily in-house. “We have a combination of so many different, unique cultures; it’s not something you can really understand as an outside consultant,” Brewer explains.

Having a real, frank conversation between the compliance team and the employees, rooted in the culture and unmediated by a vendor, proved to be an important factor in the success of the launch. “Employees aren’t ready for, certainly, the legal department to come asking them for ideas, and I think we really changed the dynamic of that conversation by doing that,” Brewer says. “I hadn’t experienced a work situation that was quite so connected on a human level.”

The Heroes are an outgrowth of Activision Blizzard’s Way2Play Team, which is the ethics and compliance team Brewer oversees. Way2Play is also the brand for ethics and compliance throughout the organization. “The word compliance can be intimidating and unfriendly; it can make people uncomfortable, doesn’t seem approachable, and people don’t know what it means,” Brewer explains. “The idea [behind the brand] is, What is the right way to play?  How do we infuse that drive to do the right thing into the conversation no matter what you’re doing, what business you’re working on, what deal you’re trying to close?”

Way2Play carries through to everything the team does, from training to policies to the code of conduct, which was redone to fit the culture. “It reflects us,” Brewer says. “It’s got images from our games, it’s interactive, it works very hard to speak in laypeople English and not read like a legal document. Because if we have policies that people can’t understand, how are we helping them navigate risks?”

Like the Heroes conference, the ongoing Way2Play trainings are often done in person, with a focus on fostering group interactions and a dialogue, so that employees feel comfortable questioning a policy or putting forth a controversial idea. “Those have been really effective tools at building relationships and partnering and making it less intimidating,” Brewer says. “We’re not police officers. We’re resources, and we’re here to help you in really tricky situations.”

Some trainings do occur online, and the challenge of delivering compelling digital training to the developers of such games as Call of Duty, World of Warcraft, and Candy Crush is not lost on Brewer. “We are never going to make content as cool as they make,” she concedes. “How do we make online training that resonates and they will pay attention to?” This is where Brewer has leveraged her younger team members’ creativity—a quality she says the legal field can sometimes neglect—and encouraged them not to be limited by traditional, off-the-shelf training. Rather than try to one-up the game designers, the team went with a retro, pixelated, Atari-like look, playing to their audience’s passion without inviting comparison. “We’ve had hundreds of people take the time to reach out and say, ‘Hey, this was awesome,’” Brewer says, “and I can tell you, people don’t take time to reach out and give kudos on their compliance training.”

In a creative industry like gaming, one of the compliance issues is conflicts of interest with employees’ personal projects. Again, rather than simply prohibiting personal projects that might be considered competitive, Brewer’s team has developed a side projects program where a group of senior employees vet submissions and decide what to greenlight. “It’s a lot of work because we have to review every single inquiry, but it’s been a really big deal because employees care about this a lot,” Brewer says. “We’ve been able to say yes to the vast majority.”

In addition to the positive feedback she’s received, Brewer sees the direct success of Way2Play in the uptick in inquiries her team receives after each training, and that’s only increased since the launch of Way2Play Heroes. “Things are actually coming forward that we can then help support,” she says. “We’ve been able to look at things and proactively address it rather than waiting until it’s a big problem. That’s been huge.”

These programs have helped Activision Blizzard continue to build a culture of transparency that encourages people to speak up when they see problems.

Guideposts of Transparency and Creative Thinking

Many of these same principles of transparency and thinking creatively are guiding posts for Jennifer Brewer in the other areas she oversees, which include the global risk and insurance program, as well as in other corporate matters. Those are areas where she works closely with trusted outside lawyers and partners. In the same spirit of what the Way2Play team works to instill in the global employee base, Brewer tries to live up to those principles herself by being direct, honest, and straightforward, and starting from the premise that partnership is based on transparency and trust. It is amazing to Brewer how even in the most complex and niche areas of the law, it is often relationships, communication, the ability to listen, and true partnership that gets everyone to the other side of a complex issue, as opposed to the technical points.



“Jen is the consummate professional. She utilizes her skills in difficult situations and reaches out to her partners for guidance in areas outside of her expertise. This team building approach puts a robust group of professionals together all pulling for a common objective and is an admirable trait. In addition, Jen is a very special person and we feel lucky to work with her.”

–Jack Flug, Managing Director, Head of U.S. FINPRO Claims