At the recent Compliance Week 2011 Conference one of the Key Note Speakers was Preet Bharara, United States Attorney for the Southern District of New York. His topic was the general principles of ethics, integrity and corporate culture. I found his remarks very appropriate for the compliance professional in evaluating a company’s overall compliance program.
He began his talk by discussing corporate culture. Some of the most egregious conduct, which violated the Foreign Corrupt Practices Act (FCPA), has come from companies with robust compliance programs. Many of these companies have had criminal conduct at all levels of the corporate hierarchy. He pointed to recent Deferred Prosecution Agreements (DPA’s) entered into by Alcatel-Lucent and Johnson & Johnson. This signaled to him that corporate culture did not meet the goals stated in the compliance programs.
Please see full publication below for more information.