News & Analysis as of

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

NAVEX Global 2014 Training Benchmarking Report Webinar: Top Takeaways & Questions

We recently hosted a webinar, “Priorities, Practices and Trends in Training” to discuss the findings from our NAVEX Global 2014 Ethics and Compliance Training Benchmark Report. Some of the key findings from the report,...more

The C-Suite Crucible and International Business: “Motivated Blindness"

In the June 2013 issue of Business Compliance (Baltzer Science Publisher, Anthony Smith-Meyer, Editor), Scott Killingsworth (Partner, Bryan Cave LLP) writes about “Ethics in the Executive Suite: The Best, The Brightest and a...more

Three Security Awareness Training Findings That Will Surprise You

As providers of ethics and compliance training solutions, we never tire of discussing topics like anti-bribery training, sexual harassment training, code of ethics training… and so many more. Lately, we have seen a real...more

UK Companies See The Value of The Code of Conduct As A Promotional Tool – Do You?

I came across this excellent article by The Red Flag Group called “Compliance Pulse: Codes of Conduct in the UK – A study of 100 codes of the largest companies listed on the London Stock Exchange.” The article outlines a...more

World Cup Finale – Compliance Lessons to be learned from Success and Failure

Over the past few weeks, I have written several articles on the lessons a compliance practitioner can draw from this year’s World Cup and the international group which runs the event, the Fédération Internationale de Football...more

Nature Or Nurture? Use Code of Ethics Training, Annual Culture Assessments to Nurture Ethical Culture

I’ve been getting more involved with our company’s social media presence lately, which is quite the double-edged sword. On the plus side, my team is very happy, I’m finding loads of great content and wonderful subject matter...more

John Bell Hood and the Measurement of Conduct Risk

Readers of this blog know I am huge Civil War buff. Growing up in Texas, I only focused on the Southern side as a youngster and while this led to a sometime myopic view of events, in my mid-20s when I did begin to study the...more

FCPA Compliance and Ethics Report-Episode 75-Roy Snell CEO of SCCE [Video]

In this episode I visit with Roy Snell, CEO of SCCE on the upcoming Nation Conference to be held in Chicago in September. ...more

Putting the Ethics Back into Healthcare Compliance

We all know someone who is a pest, a professional colleague, a friend or even a family member. I use the term affectionately and especially when I write postings that are restatements of obvious points....more

Mergers and Acquisitions Under the FCPA, Part I

Today, I begin a three-part series on mergers and acquisitions under the Foreign Corrupt Practices Act. Today I will review the pre-acquisition phase, focusing the information and issues you should review, tomorrow in Part...more

5 Elements Your Code Of Ethics Training Should Address

I read an article in EthicsMonitor by Cynthia Schoeman called How to Crack Your Company’s Code of Ethics. Cynthia makes some good points about Codes of Ethics that align with our thinking about what good employee training...more

CCOs Take Note: It’s the Culture Stupid

If CCOs are really ready to take the reins and assume a real role in the C-Suite, they need to develop more mature measurements and reports for senior management and the board of directors. We have all seen the color-coded...more

Mid-Year FCPA Report, Part II

Today, I continue my look at what I think were some of the most significant highlights from the first half of 2014 relating to the Foreign Corrupt Practices Act (FCPA). Yesterday, the focus was on corporate and individual...more

3 Questions To Help Develop Ethics and Compliance KPIs (Beyond Business Ethics Training Scores and Whistleblower Hotline Calls)

It’s no secret that ethics and compliance professionals struggle with measuring the effectiveness of their programs. Sometimes the “well, we have to do it anyway” mentality can preclude any attempt at real measurement and...more

How A Failure to Set Tone-at-the-Top Led to a Fractured Vertebra

What does ‘Tone-at-the-Top’ mean to any anti-bribery or anti-corruption program? Conversely, what if management says to do the right thing but only judges employees on their sales; what is the message that only ‘Talking The...more

Unethical Companies Capitalizing on Employee Deaths: Protect Your Reputation with Compliance Training

It came as sort of a shock to me the other day when I came across the article in Fortune titled, “The many ways companies profit from hastening employees’ deaths.” What I took away from it was that companies are taking out...more

CCO Challenges in the Healthcare Industry

Chief Compliance Officers have a tough job. It does not matter what industry they are working in, CCOs face a myriad of challenges. The healthcare industry, however, has its own set of challenges. While there has been...more

Does Your Compliance Training Inspire Employees to Follow Rules or Follow Values?

I read an article in the Wall Street Journal wherein Michael McMillan, director of ethics and professional standards at the CFA Institute, was interviewed and discussed the difference between following the rules and behaving...more

Compliance in the C-Suite

The ongoing debate whether certain executives are “too big to jail” misses the most important trend in corporate governance – namely, that criminal conduct is rising in the C-Suite. Viewed from a broad perspective, since...more

Hot Compliance Training Trends and Best Practices for Engaging Millennials: Gamification, Animation, and More!

It’s not like you don’t have enough to do – it’s like you’ve suddenly become the Chief of Education in addition to the Chief Compliance Officer. You’re expected to be up to date on all the latest trends in adult education....more

CCOs Need To Adopt Their Own Code of Conduct

As CCOs become a key player in the corporate governance world, ethics and compliance leaders are developing principles to be used by compliance pofessionals. It is a natural process that reflects the growing...more

Increasing Risks of Fraud; Compliance Failures; A Willingness to be Unethical

Cyber security, corruption and unethical behavior pose significant risks for business enterprises, according to a new survey by EY titled “Overcoming Compliance Fatigue’. At the same time business organizations may be...more

Four Reasons Why Employee Social Media Training Is Essential (Hint: It’s Not Just About Compliance!)

And before I forget, let’s make that effective social media training, shall we? Pam Moore wrote this great article “Social Media Policy & Governance: 17 Tips to Mitigate Social Business Risk.” It’s quite insightful and...more

The Final 6 Psychological Phenomena Undermining Your Compliance Training

Perhaps due to one of the aforementioned psychological reasons good people do bad things, someone has already behaved in an unethical manner. The induction mechanism postulates that the more people behave badly, the less they...more

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