We all know (and repeat every day) that corporate cultures reflect social trends and pressures. Companies face extraordinary political and social pressures, and this translates into its corporate workforce....more
Everyone is now on the culture bandwagon. For those of us pushing the issue over the last decade, welcome aboard to everyone. But once you join, the work is only beginning. ...more
The following scenario is disturbing and occurs all too often – a company receives a hotline report of misconduct occurring in its operations in a foreign country, India, for example. ...more
A corporate scandal does not occur overnight. (Thank you Bob Dylan). A CEO does not begin the day telling him or herself that today is the day to begin the Ponzi scheme or complex fraud. It is hard to imagine but corporate...more
While billionaires continue to trumpet their excess and competitive desires to fly into space, they may want to take a look around before launching themselves on the next rocket to the edge of space for a ten-minute flight....more
Forgive me for going out on a limb here. But this issue is fairly obvious. A simple question:
Should the Chief Compliance Officer be responsible for the Environmental, Social and Governance function?...more
6/15/2021
/ Business Strategies ,
Capital Investments ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corporate Social Responsibility ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Publicly-Traded Companies ,
Sustainability
LRN’s annual Ethics and Compliance Program Effectiveness Report is an important yearly event. The report is often filled with important trends and observations. For compliance officers, there is always important trends and...more
When you look at the core of several major financial scandals, it is easy to point to problems with sales incentives and corporate culture. A company can rapidly grow due to the extraordinary performance of a company’s sales...more
Ethics and compliance has to stand strong when new trends suddenly spring up. Organizations are always ready to embrace the new-fangled shiny object – in this case ESG....more
Perhaps I am little bit behind. That would be nothing new – but we are getting to the point where we no longer need to spell out ESG. Everyone knows what it means – directors, officers, employees, investors, shareholders...more
The FCPA Guidance issued by the Justice Department and the SEC says it best – “The truest measure of an effective compliance program is how it responds to misconduct.” ...more
The Ethics and Compliance Initiative is a terrific organization that provides important ethics and compliance insights and leadership. Starting in 1994, ECI has conducted a longitudinal, cross-section study of workplace...more
Chief compliance officers (CCOs) are talented professionals. As Donna Boehme always emphasizes, CCOs are subject matter experts (SMEs) in compliance risks, controls and mitigation. CCOs focus on legal and compliance risks...more
3/17/2021
/ Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Risk Management ,
Subject Matter Experts (SMEs) ,
White Collar Crimes
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
Boeing’s settlement with DOJ raises more questions than answers. While I understand that a criminal case against Boeing requires DOJ to identify one or more individuals who have committed a crime that can be fairly...more
2/4/2021
/ Aircraft Equipment ,
Airplane Accidents ,
Boeing ,
Compliance ,
Corporate Culture ,
Corporate Monitoring ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Equipment Failure ,
Ethics ,
Respondeat Superior ,
Safety Violations
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more
1/27/2021
/ Bribery ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corruption ,
Deutsche Bank ,
Enforcement Actions ,
Ethics ,
Failure to Comply ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Controls ,
Spoofing ,
White Collar Crimes
Whew! 2020 is over and we can start the New Year with hope – a fresh approach to restoring life “as it was before.” It is hard to imagine life before 2019 because no matter what – we have been changed forever....more
The Justice Department and regulatory agencies have emphasized the importance of corporate culture and the importance of ethics. As companies approach this important issue, it is important to examine a variety of strategies...more
Goldman Sachs has a new leadership role – unfortunately, it is for corruption. It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors. Instead, Goldman...more
If you speak to members of a corporate board and the C-Suite and you ask them if the company has a strong ethical culture, we all know what they will say – “Of course, we do. We have a strong commitment to our Code of...more
Boeing’s culture and safety performance continues to undermine its ability to move forward and regain trust from regulators, the aviation industry and the flying public....more
10/2/2020
/ Airplane Accidents ,
Aviation Industry ,
Boeing ,
Compliance ,
Congressional Committees ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Equipment Failure ,
Federal Aviation Administration (FAA) ,
White Collar Crimes
Corporate boards face serious challenges – business disruption from the pandemic and a slowing global economy. Directors have to focus on these two issues for at least the next 12 months....more
It is perhaps fitting that we are coming up on the one-year anniversary of the Business Roundtable’s Restatement of Corporate Purposes, which was signed by 181 corporate leaders and widely-praised for its expansion of...more
Companies do not operate in a vacuum. Political and social forces have a dramatic impact on individuals who in turn constitute a company’s workforce. ...more
We have a new poster-child for a defective corporate culture of wrongdoing. Novartis has joined the exclusive club, along with Siemens, General Motors, Wells Fargo, and others in the misconduct Hall of Fame. ...more
7/8/2020
/ Anti-Corruption ,
Anti-Kickback Statute ,
Bribery ,
Charitable Donations ,
Compliance ,
Corporate Culture ,
Corporate Integrity Agreement ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Novartis