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Ireland Takes Big Step in Protecting Whistleblowers

Earlier this year, the Protected Disclosures Act 2014 was enacted in Ireland to protect whistleblowers across all sectors of the Irish economy. Transparency International Ireland has lobbied for whistleblower legislation in...more

Boost Your Ethics and Compliance Training Efficacy: Borrowing from the Broken Window Theory to Prevent Unethical Behavior from...

The “broken window theory” is a social science or criminology theory that essentially states maintaining physical urban settings in good order will stop vandalism before it occurs. When Rudy Guiliani became mayor of New York,...more

Discipline and Rigor in Your Internal Controls

In a recent New York Times (NYT) Op-Ed by David Brooks, entitled “The Good Order”, he discussed how routine can lead to creativity. He cited to the example of three well-known authors whose habits included the following....more

How To Strengthen Your Ethics And Compliance Policy Management

People say that hindsight is 20/20. I’d say from my experiences its true. If only we could have 20/20 vision before an incident occurs, think of all the heartaches and headaches we could avoid. It would be especially helpful...more

FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions [Video]

In this episode I visit with Scott Killingsworth, partner at BryanCave on his thoughts around the compliance solutions found in private-to-private compliance obligations. ...more

TNG Premiers and Internal Controls for Gifts in a Best Practices Compliance Program

This week, 27 years ago, Star Trek – The Next Generation (TNG) made its television debut. Rarely has there a follow up to a beloved original series (Star Trek – The Original Series (TOS)) that is equally treasured by fans. ...more

West Side Story and GSK In China – Board Oversight and Tone in the Middle

Yesterday, I celebrated the anniversary of one of America’s cultural lows. But today, I am extremely pleased to open with exactly the opposite, that being one of America’s greatest gifts to the performing arts....more

AB1825 Training In 2015: “Nudging” Employees To Do The Right Thing

What factors go into decision making? Would you argue that how a situation is framed impacts how you react? Of course. Let’s consider the following situation, and apply the same logic to improve our AB1825 Training...more

Important Employee Values: Integrity and Trust

I have urged compliance professionals to avoid scare-tactics as a way to enhance their importance in the corporate organization. It is too easy to run around and spread fear about the importance of compliance to prevent a...more

Users Choose The Rules of Reddit – Which Is Why They Need Code of Ethics Training

If you haven’t heard about it already, or maybe you are just like me and try and stay out of the celebrity gossip as much as possible, there has been a leak of several celebrities’ nude photos across the internet. Celebrities...more

Governance, Compliance and Simplicity

I have always admired the ability of intelligent people to explain complex ideas in simple terms. Prosecutors have to explain complex facts and crimes to a jury....more

FCPA Compliance and Ethics Report-Episode 92-Interview with Matt Kelly [Video]

The FCPA Compliance and Ethics Report is out. In this episode I visit with Matt Kelly, editor of Compliance Week about the upcoming Compliance Week Europe and Compliance Week West conferences, the COSO framework and internal...more

How To Identify The 14 Red Flags Of Ethical Misconduct & Mitigate Them With Your Compliance Training Program: Part 2

While I sat in my last session of SCCE’s 14th Annual Compliance & Ethics Institute this past Wednesday, I turned to introduce myself to the gentleman sitting next to me. We shook hands and then I asked who he was with. I...more

When Bribery Pays, People Bribe

As Alison Taylor (Senior Managing Director, Control Risks) stated in a recent Forbes Article, “Compliance and Risk: Clearing the Org Chart Hurdle, “the traditional preventative approach to risk management is proving...more

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II [Video]

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

How To Identify The 14 Red Flags Of Ethical Misconduct & Mitigate Them With Your Compliance Training Program: Part 1

This week I had the pleasure to attend SCCE’s 14th Annual Compliance & Ethics Institute in Chicago. The first session I attended was led by Carolyn S. Egbert, Owner and Founder of Creative Solutions for Executives. Her...more

The Research Is In: Busy People Are Less Compliant

Demanding work environments are common today. But new research has identified a previously hidden cost to pressure-filled organizations, says Gretchen Gavett of the Harvard Business Review: “neglecting those secondary tasks...more

Use of Influence in the Compliance Function

One of the challenges for any Chief Compliance Officer (CCO) is how to influence the conduct and actions in a corporate environment, particularly as compliance is viewed as non-revenue generating and usually does not exist...more

Bruce Levenson Takeaways, Plus 5 History Lessons To Add “Oomph” To Your Business Ethics Training

It’s amazing to me that we’ve made it to 2014 and we’re still hearing widespread reports of racism and race-based harassment and discrimination. In 2013, the EEOC received 8,519 race-based harassment and discrimination...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

Four steps to manage your whistleblower complaints

How do you manage your whistleblower complaints? Getting employees to speak up when they see signs of wrongdoing is hard. Many employees struggle with initially "taking the plunge" (because that's how it may feel) for...more

Use of HR in Your FCPA Compliance Program [Video]

In this episode of the FCPA Compliance and Ethics Report, I discuss how HR can help to facilitate your compliance program. ...more

What Are Internal Controls, Part I [Video]

In this episode of the FCPA Compliance and Ethics Report, I begin a series on internal controls, with noted practitioner Henry Mixon. This is the first part of a two part episode on the basics of what are internal controls. ...more

Unexpected “Scientific Evidence” on the Value of Ethics & Compliance Training and Communications

A real-life situation recently provided powerful evidence of the value—and effectiveness — of ethics and compliance training and communication. When scientists want to prove the effect of something such as, for...more

How due diligence plays a role in anti-corruption compliance

With the increasing frequency and expanding scope of enforcement globally, organizations need to devote plenty of attention to anti-corruption due-diligence of third-parties that they engage. The value of due diligence is...more

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