Compliance officers and business managers need each other, whether they like it or not. The CCO has to enlist the business to own and take responsibility for compliance. Compliance cannot ensure compliance throughout an...more
Ethics and compliance programs face a rapidly approaching crossroads. Technology and data have created significant pressure on CCOs to harness innovation. This is a major opportunity for improvement but it also creates real...more
We all know the importance of teamwork and collaboration. Whatever the context, sports, business, military, and many other situations, teamwork and cooperation is essential to success. ...more
An internal investigation is like reading a good novel. You begin the journey with a general expectation of what the novel or the “investigation” is about. As every reader knows, the exhilaration is the result of following...more
The growing demand for increased diversity on corporate boards passed another hurdle. The SEC approved to Nasdaq’s proposed rule changes to mandate increased board diversity requirements. Three SEC Commissioners, including...more
8/20/2021
/ Board of Directors ,
Corporate Governance ,
Disclosure Requirements ,
Diversity and Inclusion Standards (D&I) ,
LGBTQ ,
Listing Standards ,
Minorities ,
Nasdaq ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Woman Board Members
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) -
This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more
While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures....more
An organization’s culture does not exist in a vacuum. It is communicated and executed every day. It is the guidepost by which internal and external interactions occur and is carried out by individuals in a multitude of...more
The culture bandwagon is picking up steam. Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations....more
We always read about the superstar CEO. The company’s leader who is paid millions and is the rock star of business success. Board members, shareholders and stakeholders support the leader because he/she has brought...more
Sometimes compliance issues are simple. Most times they are nuanced. This is a simple issue but it carries with it a significant message. So here goes – where is the CCO’s office?...more
We often discuss the importance of a “Speak Up” culture. We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization....more
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
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
Corporations are holding their respective breaths. SEC Chairperson Gary Gensler and his SEC colleagues are moving quickly to establish a regulatory framework for ESG disclosures. ...more
6/8/2021
/ Business Plans ,
Business Strategies ,
Capital Investments ,
Corporate Governance ,
Corporate Social Responsibility ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Sustainability
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
On March 10, 2021—by an overwhelming majority—the European Parliament passed a resolution that directs the European Commission to move forward with a formal directive (“Directive”) mandating Environmental, Social and...more
I have written extensively about the new and hot business trend – environmental, social and governance programs (“ESG”). The luster surrounding ESG has been a significant business trend and priority. Like any new trend, the...more
4/30/2021
/ Business Strategies ,
Capital Investments ,
Corporate Governance ,
Corporate Social Responsibility ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Internal Controls ,
Investment Management ,
Policies and Procedures ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Sustainability
The ESG bandwagon continues to roll – investors, companies and business media are all touting the importance of ESG for corporate success. Right behind are a number of ESG vendors, who are providing automated platforms to...more
Compliance understanding of business processes is a critical part of understanding internal controls and a company’s risk profile. Compliance officers are adept in identifying and assessing risks. In doing so, a compliance...more
We are surrounded by bias in a variety of contexts – news, politics, books and Internet information. Given the overwhelming amount of information, some find comfort in information supplied by sources with a bias. We have...more
You can draft and design the best ethics and compliance program – and then fail. You can show every compliance professional an “effective” set of ethics and compliance controls, pristine, drafted elegantly, addressing each...more