Andrew Foose

Andrew Foose

NAVEX Global

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Latest Publications


Why You Shouldn’t Relax on Pretaliation—Even if Policymakers Do

About two years ago, the Securities and Exchange Commission (SEC) made history when it brought the first “pretaliation” whistleblower enforcement action against KBR Inc., a technology and engineering firm in Houston. The...more

3/9/2017 - Benchmarks Compliance Confidential Information Dodd-Frank Employment Contract Ethics Incident Response Plans Retaliation Risk Mitigation SEC Whistleblower Awards Whistleblower Hotlines Whistleblowers

Exposing Bad Practice in Financial Services – Are New Whistleblowing Regulations Working towards Encouraging a Culture of...

September 2016 saw the enforcement of new rules by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) that aimed at increasing confidence amongst financial services employees and encouraging...more

3/4/2017 - C-Suite Executives Corporate Culture EMEA EU Financial Conduct Authority (FCA) Financial Services Industry PRA Prudential Regulation Authority UK Whistleblower Protection Policies Whistleblowers

UK Financial Services Whistleblowing Regulation Survey: Assessing The Impact Of The FCA/PRA Senior Managers Regime Whistleblowing...

NAVEX Global partnered with an independent research firm to survey compliance professionals from the UK Financial Services industry about their approach to whistleblowing and incident reporting. Our findings provide insight...more

2/2/2017 - Compliance Corporate Culture EMEA Ethics Financial Conduct Authority (FCA) Financial Services Industry Prudential Regulation Authority Retaliation Senior Management Regime (SMR) Surveys Tone At The Top UK Whistleblower Protection Policies Whistleblowers

Our Approach to Culture Assessments

In order for a business conduct and compliance programme to be successful, it must be firmly rooted and supported by company values that are reflected in a strong corporate culture. But even in the best companies, subcultures...more

2/1/2017 - Assessment Benchmarks Compliance Corporate Culture Ethics Leadership Policies and Procedures Surveys

New Federal Rules Will Affect Contractors Who Don’t Play by The Rules

Federal contractors have a powerful new incentive to play by the rules. Starting in October, businesses seeking federal contract work must disclose any labor law violations going back three years. Depending on the violation,...more

9/19/2016 - Anti-Harassment Policies Code of Conduct Competitive Bidding Corporate Culture Employee Training Executive Orders Federal Contractors Labor Law Violations OSHA Policy Management Title VII Tone At The Top Wage and Hour Whistleblower Protection Policies

Six Best Practices to Go Beyond Dutch Whistleblower Compliance

In March 2016 the Dutch Senate passed the “House for Whistleblowers” Act (Huis voor Klokkenluiders) to protect the interests of whistleblowers. This Act came into effect on 1st July. Whilst the rules currently only apply...more

7/18/2016 - Anti-Retaliation Provisions Benchmarks Board of Directors Compliance Corporate Culture Netherlands New Legislation Posting Requirements Senior Managers Whistleblower Hotlines Whistleblower Protection Policies Whistleblowers

Citadel, a $24-Billion Hedge Fund, Seeks Whistleblower Status

Just a few months after announcing the first-ever award to an outside whistleblower, federal authorities may be on the verge of expanding the reach of whistleblower incentives even further. Last week, Citadel, the...more

5/24/2016 - Anti-Corruption Anti-Retaliation Provisions CFTC Citadel Exploration Corporate Culture Dodd-Frank Futures Hedge Funds Internal Reporting Whistleblower Awards Whistleblower Protection Policies Whistleblowers

Concerns on the New UK Whistleblower Rules

The U.K.’s Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) recently began rolling out new whistleblower rules, with which financial organisations will be required to comply. These rules have not...more

4/26/2016 - Board of Directors Corporate Culture Employee Training Financial Conduct Authority (FCA) UK Whistleblower Hotlines Whistleblower Protection Policies Whistleblowers

The New FCA Whistleblower Rules: What You Need to Know

In October 2015 the Financial Conduct Authority (FCA), alongside the Prudential Regulation Authority (PRA), published new rules in relation to whistleblowing channels in banks and other financial institutions to encourage a...more

4/25/2016 - Banks Compliance Employee Training Ethics Financial Conduct Authority (FCA) Financial Institutions UK Whistleblowers

Are Concerns About the UK’s New Whistleblower Rules Misplaced?

In early April, the UK’s Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) began rolling out new whistleblower rules, with which financial organisations will be required to comply. These rules have...more

4/21/2016 - Board of Directors False Accusations Financial Conduct Authority (FCA) Prudential Regulation Authority UK Whistleblower Hotlines Whistleblower Protection Policies Whistleblowers

New UK Whistleblower Rules: A Roadmap

Financial firms in the UK are grappling with new whistleblower requirements aimed at helping to prevent another financial crisis. And while many in the financial community are nervous about the new requirements, we believe...more

3/22/2016 - Anti-Retaliation Provisions Employee Training Financial Conduct Authority (FCA) Financial Services Industry Managers Prudential Regulation Authority UK Whistleblower Hotlines Whistleblower Protection Policies Whistleblowers

EEOC Says Retaliation Claims Continue to Rise

Based on data recently released by the U.S. Equal Employment Opportunity Commission (EEOC), retaliation continues to be a growing problem in the U.S. While the number of overall charges of harassment and discrimination filed...more

3/3/2016 - Anti-Retaliation Provisions Compliance EEOC Employee Training Managers Retaliation

First DPA in the U.K. Signals Britain is Serious About Bribery & Corruption

Late last year, ICBC Standard Bank Plc, a U.K.-based financial institution with operations around the world, agreed to pay a $37 million fine and enter into a deferred prosecution agreement (DPA) with British financial...more

2/4/2016 - Bribery Compliance Corruption Deferred Prosecution Agreements Government Officials Self-Reporting Serious Fraud Office Standard Bank PLC UK UK Bribery Act

DOJ’s New Compliance Expert Brings Private Practice Insights to the Role

DOJ’s new compliance expert brings private practice insights to the department. The Fraud Section of the Department of Justice (DOJ) announced earlier this month that it has hired Hui Chen as its “full-time compliance...more

11/19/2015 - Compliance DOJ Ethics Fraud

Despite Criticism, DOJ’s New Policy On Internal Investigations Could Be a Good Thing

While naysayers believe the Department Of Justice's (DOJ’s) memo is going to result in major complications and headaches for companies experiencing government investigations, ethical companies are unlikely to be affected much...more

9/24/2015 - Board of Directors Compliance Corporate Misconduct DOJ Ethics Individual Accountability Internal Investigations Personal Liability

Culture of Corruption in the Financial Industry: A Closer Look

A closer look at new research data about corruption in the financial industry: is the industry as far behind on organizational culture as it might seem?  A recent study, “The Street, The Bull and The Crisis: A Survey of...more

6/16/2015 - Corporate Culture Corruption Criminal Prosecution Financial Institutions Managers Retaliation Risk Assessment Supervisors Training UK United States

Does Your Ethics & Compliance Policy Management Work? [Survey Says...]

The most definitive set of benchmarking data on ethics and compliance policy management ever compiled: NAVEX Global conducted an anonymous survey of nearly 900 ethics and compliance professionals about policy...more

6/8/2015 - Benchmarking Best Management Practices Chief Compliance Officers Compliance Corporate Counsel Ethics Policy Management

Policy Management Best Practice FAQs: Top 10 Questions from the Policy Management Benchmark Webinar Answered

During our recent webinar (now available on-demand), we provided an in-depth tour through the findings of our 2015 Ethics and Compliance Policy Management Benchmark Report. Webinar attendees asked a number of valuable...more

6/3/2015 - Benchmarks Compliance Ethics Policy Management Risk Assessment Third-Party Liability

Global Anti-Corruption Enforcement Trends Hit FIFA

Insights on the anti-corruption trends that contributed to the Fédération Internationale de Football Association (FIFA) scandal, and six essential characteristics of organizations whose cultures help prevent bribery and...more

5/29/2015 - Anti-Corruption Bribery Compliance Criminal Prosecution DOJ Ethics FIFA Indictments Reputation Management Sports

[Complimentary Research Report] NAVEX Global's 2015 E&C Policy Management Benchmark Report

Policy management has been — and remains — a maturing business practice. As a result, many compliance professionals are not working against industry benchmarks to answer such questions as: - How much are other...more

5/27/2015 - Benchmarking Best Management Practices Chief Compliance Officers Compliance Corporate Counsel Ethics Policy Management

[Webinar] Benchmarking Your Policy Management Program - May 21, 10:00am PT / 1:00pm ET

Join this free webinar to hear compelling survey results and answers to questions such as: What are organizations doing to address policy management today? What are E&C leaders’ top policy management...more

5/14/2015 - Best Management Practices Chief Compliance Officers Compliance Compliance Commitees Corporate Counsel Enforcement Ethics Policy Management Webinars

Data Privacy Challenges & Considerations for Cross-Border Ethics & Compliance Investigations

What investigators need to know—and do—to adhere to data privacy laws relating during ethics and compliance investigations. Investigations of potential misconduct can be taxing for any organization. But for...more

4/14/2015 - Anti-Bribery Compliance Cross-Border Data Privacy Ethics Internal Investigations International Labor Laws Multinationals Outside Counsel Popular Privacy Laws

Seven Training Imperatives to Address Your Biggest Cyber Security Risk: Employee Behavior

One of your best defenses against a cyber attack? Your employees. Make sure they are trained on their role in protecting your organization. There are pros and cons to the digital world that we all live in. Pros include...more

3/31/2015 - Bring Your Own Device Compliance Corporate Counsel Cybersecurity Ethics Mobile Devices Popular Risk Assessment Risk Management Training

The Future of U.K. Enforcement of Financial Crimes: Four Clues for 2015

The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more

3/18/2015 - Compliance Corporate Criminal Fines Corporate Culture Corporate Governance Criminal Prosecution Deferred Prosecution Agreements DOJ Enforcement Actions Financial Conduct Authority (FCA) Financial Crimes SEC Self-Reporting SFO UK UK Bribery Act Whistleblower Awards Whistleblowers

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