In January 2019, the US Attorney for the Eastern District of Michigan returned an indictment against four executives from Audi, a Volkswagen subsidiary, for their participation and direction of Audi’s emissions-cheating...more
2/13/2019
/ Audi ,
Automotive Industry ,
Carbon Emissions ,
Compliance ,
Corporate Culture ,
Corruption ,
Criminal Conspiracy ,
Criminal Investigations ,
Criminal Prosecution ,
Enforcement Actions ,
Ethics Breach ,
Indictments ,
National Emissions Standards ,
Volkswagen ,
White Collar Crimes
The corporate scandal landscape is littered with important examples of governance failures surrounding corporate ethics and mishandling of harassment and sexual assault controversies. ...more
2/12/2019
/ #MeToo ,
CBS ,
Code of Conduct ,
Compliance ,
Corporate Culture ,
Employee Misconduct ,
Employer Liability Issues ,
Ethics ,
Google ,
Risk Management ,
Sexual Harassment ,
Tone At The Top
There is no question that corporate leaders, senior executives, legal and compliance staff, and internal auditors recognize the value of an ethical corporate culture. ...more
Employee hotlines are – sorry about this – a “hot” topic these days in compliance.
NAVEX Global’s recent study confirmed the importance of an effective hotline system. Companies that implement robust and widely-used...more
This is my favorite topic. New trends come and go in the compliance field, while effective solutions and strategies slowly but surely take hold. Eventually, an effective compliance practice or strategy becomes a “best...more
Maybe I am getting slow in my old age – or just maybe I am losing a step or two. We all face that inevitable question – and perhaps, for me, it is best illustrated when I come up with yet another in my series of profound...more
The government has emphasized the dangers of a paper compliance program, meaning a compliance program that is written down but not implemented. ...more
I do not think there is much disagreement on the basic purpose of an ethics and compliance program. After all, one of the primary sources for compliance programs continues to be the United States Sentencing Guidelines which...more
It is distressing that corporate boards, CEOs and senior managers receive adequate training. Many CCOs are reluctant to face this issue and recommend (or insist) on appearing before their corporate boards to conduct such...more
We all enjoy citing Supreme Court Justice Potter Stewart’s famous description relating to obscene materials, “I know it when I see it.”...more
Right up front, I want to confess. I am a lawyer, and I love being a lawyer. So forgive me for this posting and perhaps my narrow-minded view but I have to take a moment to express some concerns about ethics and compliance....more
Compliance officers have a difficult job.
So why are so many people interested in joining the profession?
At bottom, compliance professionals are inspirational professionals and inspired by their mission. Compliance...more
The United Technologies FCPA settlement underscored, once again, the harm to a company when lawyers fail to do their job.
As outlined in the SEC settlement, an in-house attorney at Otis Elevator was required to review and...more
Language communicates more than just words – indeed, the use of language reflects much more than simple communication. Often, a person’s language reveals an attitude, a feeling, a perspective, and much more about a person. ...more
Corporations experience numerous tests of character. Perhaps one of the most important is how the company responds when facing potential misconduct. ...more
In these turbulent times in our country, there is a premium on the concepts of empathy and compassion. A successful leader in any organization has to demonstrate his or her ability to feel compassion....more
A compliance program is a continuously evolving process. The lifeblood of a compliance program is its ability to refresh itself, to incorporate new information and data, and adjust to meet new challenges....more
Maybe I am missing something, but everyone is jumping on the culture bandwagon. Regulators like to speak about it; prosecutors like to emphasize it – everyone likes to talk about it as a way to encourage corporate leaders to...more
There are a lot of talented CEOs. Some remarkable leaders, innovators and eloquent spokespeople for their companies. In several recent experiences, I have been befuddled by some CEOs....more
We often hear the compliance refrain on the importance of tone-at-the-top – meaning when the board, the CEO and senior executives demonstrate by communications and by conduct their commitment to a culture of ethics and...more
Research has consistently demonstrated that an ethical corporate culture results in increased profits and sustainable growth. Companies with a positive culture have lower rates of employee misconduct, increased employee...more
Corporate commitment to speak up cultures is suffering. The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey contained a critical finding – corporate instances of retaliation against employee...more
5/18/2018
/ Bribery ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Ethics ,
Internal Reporting ,
Ombudsman ,
Retaliation ,
Risk Management ,
Whistleblowers ,
White Collar Crimes
As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives. So, our kids start to speak up...more
The chief compliances officer is the guardian of a company’s most important intangible asset – its culture. Everyone at a company is responsible for a company’s culture; the board of directors, CEO, senior executives play an...more
We continue to read headlines of whistleblowers receiving large, sometimes, multi-million-dollar awards after successful prosecutions of companies for a variety of criminal and civil offenses. ...more