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Corruption Ethics Corporate Misconduct

Society of Corporate Compliance and Ethics...

The Dark Patterns Behind Corporate Scandals

Professors Guido Palazzo and Ulrich Hoffrage are skeptical. When they hear that there was a bad apple at the core of a scandal, they are hesitant to accept that explanation. Instead, they argue in this podcast and in their...more

American Conference Institute (ACI)

The Big Picture: Anti-Corruption Enforcement and Integrity Program Developments in Brazil

The last several months brought forth major reforms to Brazil’s anti-corruption regulations and enforcement environment, including in the way that Brazilian companies are expected to enhance their compliance programs....more

Wiley Rein LLP

[Podcast] "Dumplings,” Diamonds, & Plea Deals: Brazil’s Operation Car Wash

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Power and corruption … two sides of a wicked coin. In this podcast, hosts Tatiana Sainati and Diana Shaw tell the stories of the world’s largest, most salacious corruption scandals and explore the myriad ways in which...more

Thomas Fox - Compliance Evangelist

Global Business Ethics Survey: Part 2 – Addressing Workplace Misconduct

The Global Business Ethics Survey (GBES) conducted by the Ethics & Compliance Initiative (ECI) provides valuable insights into workplace ethics and compliance from the perspective of employees. I recently had the opportunity...more

The Volkov Law Group

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

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Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and...more

The Volkov Law Group

Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of...

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If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class.  Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more

The Volkov Law Group

The Importance of Accounting and Internal Controls (Part I of II)

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Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more

The Volkov Law Group

NAVEX Annual Hotline and Incident Report: A Mixed Bag of Reporting Trends

The Volkov Law Group on

NAVEX recently released its annual Hotline and Incident Management Report.  Given NAVEX’s strong position in the hotline service market, NAVEX has access to a large volume of reporting data.  As a result, its annual report is...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

The Volkov Law Group on

On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

The Volkov Law Group

Measuring and Reporting on the Organization’s Culture (Part III of IV)

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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

Latham & Watkins LLP

White Collar & Compliance Academy 2021 - Die Zukunft

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Compliance & Investigations im Jahr 2025 - „Wirksame Compliance erfordert ganzheitliche Ansätze.“ Was ist für die Themen „Compliance & Investigations“ im Jahr 2025 zu erwarten? Fünf Thesen von Prof. Dr. Thomas Grützner...more

The Volkov Law Group

Danger! Danger!: Retaliation Against Employees is Increasing (Part II of II)

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Selection of Investigative Counsel

Dan Dunne, in a Compliance and Ethics Professional article, entitled “Foxes and henhouses: The importance of independent counsel”, said a critical element in any investigation is “fair and objective evaluation by the...more

The Volkov Law Group

A Speak Up Culture Depends on Follow Through and Accountability

The Volkov Law Group on

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

The Volkov Law Group

Fixing a Toxic Corporate Culture

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We all know about the high-profile scandals that lawyers and compliance officers point to as examples of weak to non-existent ethical corporate cultures. ...more

The Volkov Law Group

When Company Supervisors and Managers Engage in Misconduct

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We all know the phrase – “A fish rots from its head.”  A perfectly accurate statement as to how corporate culture can suffer from leadership failures or C-Suite misconduct.  But there is much more to corporate culture than...more

Thomas Fox - Compliance Evangelist

Farewell to the Easy Rider and How to Scandal Proof Your Company: Part 1

Fonda’s life informs today’s blog post as we begin a multi-part series based upon the recent Harvard Business Review (HBR) Spotlight on White Collar Crime. Today, we begin the article by Paul Healy and George Serafeim,...more

The Volkov Law Group

Board Members Should Take Note — Delaware Supreme Court Issues Important Decision on Caremark Compliance Standard

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I have long predicted that corporate board members are in for a rude awakening. Corporate boards have to improve their ability and knowledge surrounding supervision and monitoring of a company’s ethics and compliance...more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Creeping Man and Risk Management by the Board

CCO reporting to the Audit/Compliance Committee must be structured carefully to promote ethics and compliance. Here are five best practices to help guide the reporting....more

The Volkov Law Group

Corporate Culture and “Benign” Indifference

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People are good at convincing themselves that everything is okay, despite troubling indications. Sometimes it is easier to ignore warning signs than to face the harsh reality....more

Troutman Pepper Locke

New DOJ Guidance Instructs Corporations on Hallmarks of an Effective Compliance Program

Troutman Pepper Locke on

On April 30, the Criminal Division of the Department of Justice released an update to the Fraud Section’s February 2017 guidance document titled “Evaluation of Corporate Compliance Programs.” ...more

Littler

Department of Justice Releases Guidelines for Effective Corporate Compliance Programs

Littler on

On May 1, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) released updated guidance for prosecutors to utilize in assessing whether an organization had in place “an adequate and effective corporate...more

Thomas Fox - Compliance Evangelist

ECI’s 2018 Global Business Ethics Survey Retrospective

Next week, in a five-part podcast series, I interview Ethics and Compliance Initiative (ECI) Chief Executive Officer (CEO) Patricia J. Harned, Ph.D. In the series we consider the key findings from ECI’s Global Business Ethics...more

Thomas Fox - Compliance Evangelist

Farewell to John McCain and Integrity in Your Organization

John McCain died over the weekend. I cannot think of a much better example of someone who continually sacrificed himself for his country than McCain. ...more

Thomas Fox - Compliance Evangelist

What is the role of a CCO in strengthening the ethical culture of an organization?

Today, I want to consider what is the role of a Chief Compliance Officer (CCO) in strengthening the ethical culture of an organization.  This blog post is based on, in part in an interview I did with Eric Feldman from...more

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