GC Sidebar: Rishi Varma, CLO at Cargill

In this GC Sidebar Season 2 episode, Paragon Legal CEO Trista Engel speaks with Rishi Varma, Chief Legal and Ethics & Compliance Officer at Cargill, about leading through complexity, building modern legal teams, and navigating uncertainty.

Rishi shares how he’s designing a legal function equipped for today’s environment, including developing AI systems grounded in 160 years of institutional knowledge and enabling teams to operate with greater speed and precision. He also discusses the importance of cultivating talent that can think strategically, adapt quickly, and thrive in ambiguity.

Rishi also reflects on how legal leaders can balance innovation with accountability, ensuring that technology enhances decision-making while keeping human judgment at the center.

Full episode now available.

Read the Full Conversation

Prefer reading over watching? Below is the complete transcript from our GC Sidebar interview with Rishi Varma, Chief Legal and Ethics & Compliance Officer at Cargill.

Trista Engel:

Welcome to GC Sidebar, a short and sharp conversation series with leading general counsel about the decisions, reflections, and people behind the title.

I’m Trista Engel, CEO of Paragon Legal, and today I’m joined by Rishi Varma, Chief Legal and Ethics & Compliance Officer at Cargill, one of the world’s largest privately held food and agricultural companies.

Rishi is a four-time general counsel who balances leading legal for a critical global company while raising three kids and maintaining a deep commitment to equal justice—work that was recently recognized with the 2025 Scales of Justice Award. Rishi, thank you so much for joining me today.

Rishi Varma:

Thanks for having me.

Trista Engel:

Let’s jump right in. What’s one thing you’re most focused on for 2026, and why?

Rishi Varma:

We’re living in a world of accelerated uncertainty and complexity, and that hasn’t made things any easier for the legal profession.

What I’m really focused on is building strategic talent within my department so we can deliver solutions without getting stuck searching for answers. That means combining AI-enabled tools with human insight.

On the AI side, we’re thinking about how to eliminate the need to search for data so our teams can focus on what they were hired to do: generate insights and make decisions. I think of it as combining human ingenuity with AI precision.

We’re also working on building what I call a “better brain” for Cargill—leveraging our 160 years of institutional knowledge. If we can train systems to understand how we’ve historically assessed and negotiated risk, that makes our lawyers more effective.

But technology alone isn’t enough. You need the right talent structure. You need people in the right roles, and you need to create pathways for growth based on capability, not just tenure. So we’re building both the technology and the talent model together, with the flexibility to scale as complexity increases.

Trista Engel:

I love how you’re thinking about that, especially because so many teams are under pressure to adopt AI, and often the challenge is the data and the people. It sounds like you’re addressing those first so you can actually get to better outcomes.

Rishi Varma:

That’s exactly right.

Trista Engel:

What’s the most valuable lesson you’ve learned as a GC?

Rishi Varma:

You don’t have to know everything.

What matters is knowing how to process uncertainty. The lesson for me has been learning how to slow things down so you can move faster. That means breaking complex issues into smaller questions, gathering the right information, and building toward a recommendation.

It also means relying on the people around you.

COVID was a great example. Legal teams were being asked questions no one had answers to—when it was safe to return to the office, how to manage risk, how to protect employees. Those aren’t things you learn in law school, but you do learn how to navigate uncertainty.

So the real skill is not knowing everything, but knowing how to work through uncertainty effectively.

Trista Engel:

That’s great advice, especially in a world where so much of what we’re facing doesn’t have clear precedent.

What’s one career moment that changed your trajectory?

Rishi Varma:

My career hasn’t been linear, and I think that’s been a strength.

One defining moment was when I was at Hewlett-Packard during the company’s separation into two businesses—a $110 billion split. I had very little experience with something of that scale, but I raised my hand to lead the legal work.

That experience pushed me in ways I hadn’t been pushed before. I learned how to manage large, cross-functional teams, how to solve problems in real time, and how to communicate effectively with very different audiences—from working teams to the board.

It also gave me visibility and allowed others to see what I was capable of. That moment really accelerated my career.

Trista Engel:

There’s so much in that—raising your hand, getting exposure across the business, and learning how to communicate effectively with different audiences. Those are opportunities you wouldn’t have had if you hadn’t stepped forward.

Rishi Varma:

Exactly.

Trista Engel:

GCs today have a wide range of resourcing options beyond full-time hires and outside counsel. What’s your approach?

Rishi Varma:

My approach has evolved over time.

Earlier in my career, I focused heavily on cost efficiency—how to expand resources while staying within budget. Now I think more about how to eliminate capacity constraints altogether.

That starts with technology. Where can we automate? Where can we remove friction? Where can we standardize work so our teams can focus on higher-value, strategic work?

If we can solve for capacity through technology, that’s always my first step.

But there will always be situations where you need additional people—whether for a specific project, a surge in workload, or a specialized skill set. In those cases, we look to the market and bring in the right resources in a targeted way.

So it’s really about combining technology and talent to create flexibility and scale.

Trista Engel:

That’s a really helpful framework. Thank you.

When you’re not lawyering, where are you most likely to be found?

Rishi Varma:

My wife and I travel quite a bit, often combining business travel with personal time. Our oldest lives in Hong Kong, so we find ourselves in Asia more than we expected.

Beyond that, I love a good meal and spending time around the table with friends. And I play squash with my daughters, who both play in college. I taught them how to play, but now it’s hard to get them back on the court with me because they’re so much better.

Trista Engel:

The student becomes the teacher.

Rishi Varma:

Exactly.

Trista Engel:

And the bonus question: Paragon turns 20 this year. What’s one memory from 20 years ago that stands out?

Rishi Varma:

Twenty years ago, our kids were very young—about five, three, and one—so we were definitely in that phase of life.

One of my favorite memories is our weekends together as a family. We’d all pile into the bedroom, watch movies, and just spend time together. It was simple, but it was special.

As your kids grow up, you realize how quickly those moments pass, so I really value those memories.

Trista Engel:

That’s such a great reminder for those of us still in that phase.

Rishi, this was such a great conversation. Thank you so much for sharing your insights and your story.

Rishi Varma:

This was a lot of fun. Thank you.

Trista Engel:

That’s a wrap on today’s episode of GC Sidebar. Catch more great conversations at paragonlegal.com. Thanks for tuning in.