Stephen Naughton

Steve Naughton, a Senior Adviser with StoneTurn, has more than 30 years of experience in managing risks and compliance efforts as an outside attorney, in-house counsel and Chief Compliance Officer for large multinational corporations. Specifically, Stephen has served as a Chief Ethics and Compliance Officer for PepsiCo, Inc. and Kimberly-Clark Corporation, as well as overseeing the litigation function for both PepsiCo and The Quaker Oats Company.

Most recently, Steve was the Vice President and Chief Compliance & Ethics Officer of Kimberly-Clark, a multinational corporation operating in more than 100 countries. In this role, he managed all of the company’s compliance efforts. He specifically led the company’s Anti-Bribery and Foreign Corrupt Practices Act Compliance programs, and supervised programs relating to fair trade and antitrust compliance. He conducted enterprise-wide risk assessments and formulated appropriate corrective action plans.

Prior to that role, Steve was the Senior Vice President and Chief Litigation Officer of PepsiCo. In that position, he managed all of PepsiCo’s litigation and led PepsiCo’s defense of high-visibility putative class action suits related to the defense of marketing claims.

Before leading the litigation group at PepsiCo, Steve served as its Chief Ethics and Compliance Officer, where he led the transformation of the Compliance function into an integrated business capability within operating divisions. He also established risk management reviews to help business anticipate and respond to potential issues in key functions, such as privacy, data security, antitrust, fraud and financial reporting. Besides PepsiCo being recognized as one of Ethisphere’s World’s Most Ethical Companies for every year in which Steve served as its Chief Ethics and Compliance Officer, its Compliance program received a perfect score in a review by the Dow Jones Sustainability Index. Steve has also been recognized as a Top Compliance Mind by Compliance Week.

Before working at PepsiCo, Steve was the Chief Litigation Counsel at The Quaker Oats Company where he also held a number of other roles in a wide array of areas in the Legal Department. He actively participated in merger and acquisition due diligence around the sale of Quaker to PepsiCo.

Steve began his career as an attorney with Rooks, Pitts and Poust, focusing on medical malpractice, product liability and general commercial litigation. He was also elected a partner at Pope Ballard Shepard and Fowle, Ltd. He is a member of State Bar of Illinois.

Areas of Practice