News & Analysis as of

Happy Birthday Dodd-Frank: The Whistleblower Program Milestones and How They’ve Impacted Business Ethics Training

Did you have some cake? Break out the balloons? While it’s hard to believe, it is true. Our little Dodd-Frank, signed into law by President Obama in 2010, is already four years old and about ready for pre-school. Although we...more

The Absence of a CECO and the GM Fiasco

This is a posting that I have wanted to write since the GM scandal occurred. I have to start with a rhetorical question – Would the GM debacle have occurred if GM had an independent and empowered Chief Ethics and Compliance...more

Thinking Through Risk Rankings of Third Parties

One question often posed to me is how to think through some of the relationships a company has with its various third parties in order to reasonably risk rank them. Initially I would break this down into sales and supply...more

How Vendors Can Add Value to Your Resource-Constrained Ethics And Compliance Training Program

Too many times we see the providers of ethics and compliance services disappear after they have sold an ethics and compliance training program or ethics and compliance policy management system. ...more

Five Ways for CCOs to Enhance Their Professional Qualifications and Status

Chief Compliance Officers are the rising professional stars in the corporate employment landscape (along with IT professionals who have practical perspectives). The profession is at an important test – where will the...more

Five Most Common Weaknesses in Anti-Corruption Compliance Programs

In this Internet-age of ADHD and simplistic thinking, I thought I would contribute this week by putting together some lists of common themes in the ethics and compliance world. Unfortunately, we are all addicted to quick...more

Five Keys to Reducing Behavior Risk During Mergers, Acquisitions and Other Major Organizational Change

A recent blog post by Ethics Resource Center President Pat Harned, reported on findings from the ERC 2013 National Business Ethics Survey (NBES) of significantly more observed misconduct in companies that are under stress...more

NBA Scores Hit With Music Video Fan Code of Conduct – Why Not Apply The Same Concept To Business Ethics Training?

I haven’t been to an Atlanta Hawk’s basketball game this season, but apparently they are heating it up with their video fan Codes of Conduct. In November, the Hawks released a video Code of Conduct, modifying Robin Thicke’s...more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Bankers Swear To An Ethics Oath; Have They Sworn to Take Ethics and Compliance Training?

My mother enrolled me in Girl Scout Daisies when I was six. It’s an all-girl organization that seeks to help out the community and give back to those less fortunate, and is basically the precursor to becoming a Girl Scout...more

Termination of a Third Party or Breaking Up Should Not Be Hard To Do

One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine. Not only does...more

The Majors, The Minors and Antitrust Training

In my last antitrust training blog, I admitted I didn’t know much about it and that I frankly thought of the topic as much less popular than others in most ethics and compliance training libraries. After writing about it,...more

Practitioners Share Their Top Ethics & Compliance Training Objective -- And It's Not What You Might Expect

Ninety percent of survey respondents from NAVEX Global's 2014 Ethics & Compliance Training Benchmark Report, cited their top ethics and compliance training objective as “Create a culture of ethics and respect.” This was...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part III

So, now you’re ready to start your culture audit… Some key questions you want to ask before you start are: Do I have the support of Executive leadership? If not, go back to your E&C steering committee and work through...more

Are We Giving Up on Ethics & Compliance Programs?

The recently released 13th Global Fraud Survey from EY notes that, despite an aggressive enforcement environment focused on fraud, bribery and corruption, “the percentage of companies that have anti-bribery/anti-corruption...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part I

We’ve talked a lot in our Tales from the Crypt about the signs to watch for that indicate something’s gone wrong, from minor cultural twists to lapses of integrity that are tantamount to criminal activity. We all wish we had...more

Do you have a whistleblower culture? You should!

Every organization should strive for honesty amongst its employees and stakeholders. This element allows for complete dedication to the organization's mission, and success. Encouraging a whistleblowing culture within the...more

Comprehensive Anti-Bribery Program

If your operations are global, implementing a comprehensive anti-bribery program is likely one of your top priorities. Given the complexity and diversity of the activities that must be addressed in an anti-bribery program,...more

Designing Cost Effective Risk Assessment Programs May 21, 2014 [Video]

The foundation of every anti-corruption ethics and compliance program is a risk assessment. It is important to design and implement a process to conduct an initial risk assessment, to update the risk assessment, and to ensure...more

Whistleblowers are important | Ensure yours understand their benefit

Over the last few years, we've seen how the power of whistleblowers can effect change, hold companies accountable and stop corruption. The spotlight on the critical role they could have played is seen in the absence of them...more

Code of Ethics | Code of Conduct - What's the Difference?

The terms "Code of Ethics" and "Code of Conduct" are often mistakenly used interchangeably. They are, in fact, two unique documents. Codes of ethics, which govern decision-making, and codes of conduct, which govern...more

Employee Culture Surveys: Low-Cost Critical Information

It is always amazing to me how reluctant people are to ask direct questions. Interviewers freeze up when they have to ask the big question – “Did you steal the money?” Boyfriends are afraid to ask a girlfriend, “What is the...more

Code of Conduct, Compliance Policies and Procedures-Part II

This week, I am reviewing the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and...more

Battling Your GRC Demons: Solving The Top 5 Concerns of Compliance Professionals

Organizations face mounting pressure to deal with their ethics and compliance infrastructures. Increased scrutiny, global regulations, enforcement actions, and the reputational need to be viewed as a company driven by ethical...more

Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

In this issue: - Recent Trends and Patterns in FCPA Enforcement - Recent Trends and Patterns in FCPA Enforcement Enforcement - Actions and Strategies - Statistics - Types of Settlements...more

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