Companies face a daunting challenge to reassure and regain trust and integrity with employees. CEOs should view the current situation as an opportunity to improve a company’s culture by building on the company’s trust and...more
7/4/2020
/ CEOs ,
Coronavirus/COVID-19 ,
Corporate Culture ,
Customers ,
Employer Responsibilities ,
Health and Safety ,
OSHA ,
Personal Protective Equipment ,
Public Health Emergency ,
Sick Employees ,
Social Distancing ,
Workplace Decontamination ,
Workplace Safety
The often-used phrase of “tone at the top” is inartful in my view – an organization’s leadership culture is defined much more broadly than the word “tone” implies. A company’s culture extends well beyond senior leadership...more
6/12/2020
/ Blue Bell Creameries ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Ethics ,
Food Contamination ,
Food Manufacturers ,
Food Safety ,
Food Supply ,
Listeria ,
Quality Control Plan ,
White Collar Crimes
Boeing is still under investigation. A grand jury is investigating potential safety and obstructions allegations. Congressional investigations are continuing....more
Boeing’s 737 Max problems began over ten years ago. Facing competitive pressure from Airbus, Boeing embraced the 737 Max as its competitive savior. After two horrific crashes killing a total of 346 people, the FAA ordered...more
When a company suffers from serious misconduct, the source of such a failure usually lies in its corporate culture. I know this theory sounds relatively obvious, but bear with me here....more
The NAVEX Global Report is based on 2019 data before the pandemic occurred. Nonetheless, the insights are helpful and provide important insights that can be applied in a post-pandemic time....more
Human Resources and Compliance have always had a natural and tight bond, assuming that there is no territorial or in-fighting political disputes. In this new COVID-19 pandemic era, the HR and Compliance partnership is even...more
Like all compliance programs, a company lives or dies based on its ethical culture. A company with a poor culture that operates in a concentrated competitive market has significantly higher antitrust risks than companies...more
We all are familiar with the “horror” stories circling numerous infamous corporate scandals – Wells Fargo, Boeing, General Motors, Airbus, Ericsson, HSBC and on and on. When you read about each of these scandals, layer by...more
We all know that economic incentives are critical to promoting performance. Going back to the days of Adam Smith, the U.S. economic growth is the result of a basic motivation – hard work can result in significant...more
Chief compliance officers are heroes. They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more
3/3/2020
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corruption ,
Ethics ,
Internal Controls ,
Leadership ,
Risk Management ,
White Collar Crimes
Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations. Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more
The Justice Department “listens and learns” from companies and compliance practitioners. As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more
2/27/2020
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Confidentiality Policies ,
Corporate Culture ,
Corruption ,
Department of Justice (DOJ) ,
Incident Response Plans ,
Internal Controls ,
Internal Reporting ,
White Collar Crimes
We often hear about the dangerous risk to a company’s culture from rigorous sales incentive programs. Like most issues, the answer to this issue is not cut and dried....more
When reviewing a major enforcement case, I always ask two basic questions:
What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more
2/6/2020
/ Airbus ,
Aviation Industry ,
Bribery ,
Compliance Management Systems ,
Corporate Culture ,
Corruption ,
Criminal Prosecution ,
Defense Sector ,
Deferred Prosecution Agreements ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
ITAR ,
Military Contracts ,
National Security ,
Regulatory Violations ,
Settlement Agreements ,
Statutory Violations ,
White Collar Crimes
The path of the compliance profession has been remarkable. Recently, I have seen a number of tweets and postings from compliance thought leaders touting the accomplishments of compliance and the transformation of the...more
1/17/2020
/ Analytics ,
Anti-Corruption ,
C-Suite Executives ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Corporate Culture ,
Corporate Governance ,
Leadership ,
Risk Management ,
Senior Managers ,
Technology ,
White Collar Crimes
As everyone knows, I am an eternal optimist. Being a cynic always leads to negative energy and results. As a former federal prosecutor, I am deeply committed to the idea of doing the right thing....more
1/15/2020
/ Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Corporate Misconduct ,
Innovative Technology ,
Leadership ,
Risk Management ,
White Collar Crimes
2019 was a big year for ethics and compliance. In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more
1/14/2020
/ Analytics ,
Automation Systems ,
Chief Compliance Officers ,
Compliance ,
Cooperative Compliance Regime ,
Corporate Culture ,
Corporate Governance ,
Data Management ,
Department of Justice (DOJ) ,
Ethics ,
Federal Sentencing Guidelines ,
Innovative Technology ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Violations ,
Speak-up Cultures ,
Strategic Planning
Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more
1/10/2020
/ Anti-Corruption ,
BP ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Ethics ,
Internal Reporting ,
Oil & Gas ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Speak-up Cultures ,
Supervisory Guidance ,
Tone At The Top ,
Whistleblowers ,
White Collar Crimes
Corporate cultures do not operate in a silo or free from external influences.
Yet again, another profound grasp of the obvious. Employees, managers and senior leadership all bring their own experiences, perspectives,...more
12/12/2019
/ Anti-Corruption ,
Compliance ,
Conflicts of Interest ,
Corporate Culture ,
Corporate Governance ,
Corruption ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Political Expression ,
Risk Management ,
Tone At The Top
The Justice Department and the SEC have launched criminal and civil accounting fraud investigations against Under Armour. The sportswear maker has been suffering a rapid revenue decline over the last few years....more
11/12/2019
/ Accounting Fraud ,
Books & Records ,
Corporate Culture ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fashion Industry ,
Popular ,
Quarterly Report ,
Reputation Management ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
In today’s aggressive enforcement environment, corporate board members have a target on their respective backs. Even with robust liability insurance, corporate boards are operating in a state of “ignorance is bliss.” ...more
Without belaboring all the feel good and esoteric discussion surrounding societal ethics and applying these concepts to business ethics, I would suggest that we focus on the term “business ethics” by focusing on the concept...more
The twist and turns of our political world amid the ongoing controversy surrounding whistleblower reporting has focused attention on an important issue – encouraging whistleblowers as part of a speak up culture and...more
We all are living in an era of rapid technological development – everyone understands that basic point. Even in a small way, we can observe the impact in ethics and compliance. Start with the simple transition from “paper”...more