Code of Conduct

News & Analysis as of

DOJ Criminal Prosecution of Wells Fargo: What to Expect?

Compliance and enforcement headlines have focused on the Wells Fargo scandal. And for good reason. On September 8, 2016, the Consumer Financial Protection Bureau, the Comptroller of the Currency and the Los Angeles...more

What Will Be the Final Fallout from Wells Fargo?

Crimson flames tied through my ears... Rollin’ high and mighty traps... Pounced with fire on flaming roads... Using ideas as my maps... “We’ll meet on edges, soon,” said I... Proud ‘neath heated...more

[Webinar] 2016 Ethics & Compliance Virtual Conference - Harnessing the Business Value of an Ethical Culture - November 15th,...

Join professionals in ethics and compliance, human resources, legal, audit and training for the annual 2016 Ethics & Compliance Virtual Conference! Learn strategies to help you build a better governed, more risk-aware, and...more

Match Made in Heaven: Compliance and Human Resources

The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the personnel involved, compliance has to establish and maintain effective working...more

Who is Responsible for a Company’s Mood in the Middle? – the Wells Fargo Fiasco

Wells Fargo’s cultural tone is not easily segregated between “top,” “middle” and “bottom.” Despite the recent cross-selling scandal, in which the CFPB led an enforcement action whose fines total a whopping $185 million,...more

Wells Fargo Week: Part V – Compliance is the Answer

I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more

Wells Fargo Week: Part IV – Senior Management, the Board and Corporate Governance Issues

At least he fessed up that it was not the (non) rogue 5,300 employees that were responsible for defrauding Wells Fargo customers. At the Senate Banking Committee hearing, held on Tuesday 20th September, Wells Fargo Chief...more

Wells Fargo Week – Part II: Tones at the Tops

Tone at the top is the single most ubiquitous phrase in compliance. However, I heard it phrased in a manner last week which not only made sense but explained why it is the most used phrase. It came from Vanessa Rossi, FCPA...more

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

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Three Considerations For Drafting A Code of Business Conduct

Although the Securities and Exchange Commission does not require that a company adopt a code of business conduct and ethics, I would be very surprised to hear of an SEC reporting company that has not adopted such a code. ...more

Competition and consumer law update for the food and beverage sector

Results of a Food and Grocery Code of Conduct supplier survey suggest retailers can improve compliance with the Code - One year has now passed since Australia's two major supermarkets signed up to the Food and Grocery...more

Hallmark 2 – Code of Conduct and Compliance Policies and Procedures

The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and...more

SEC Whistleblower Enforcement Settlement Reminds Private Fund Sponsors to Review Organizational Policies and Procedures for...

A recent SEC settlement of whistleblower charges should serve as a useful reminder for private fund sponsors to conduct a comprehensive review of their policies and procedures. On August 10, 2016, the SEC announced that...more

My Organization's Code of Conduct is Good - How Can I Make It Great?

Too long. Too complicated. Too dense. Sound familiar? If your code of conduct isn’t a document you’re proud to share with your employees, customers, board and C-suite—or if your organization has recently had a big change...more

Unlocking the EU General Data Protection Regulation: A practical handbook on the EU's new data protection law: Chapter 12: Impact...

Why does this topic matter to organisations? A significant aspect of complying with EU data protection law is demonstrating compliance—making it evident to DPAs that an organisation is meeting its obligations. Three of...more

FTC Steps Up Activity on APEC Cross-Border Privacy Certification: Issues Warning Letters to 28 Companies Claiming Certification

The Federal Trade Commission (FTC) has issued warning letters to 28 companies that claim to be certified participants in the Asia-Pacific Economic Cooperative’s (APEC) Cross-Border Privacy Rules (CBPR) system on their...more

Collegiality in the Workplace – Not Authorized by NLRB

Collegiality in the workplace is the goal of every employer in order to provide the proper atmosphere for productive employees. Many employers have taken this desire to heart by publishing rules that encourage collegiality...more

NLRB Strikes Healthcare Facility Conduct Rules

The National Labor Relations Board (NLRB) has provided clear signals that the unique, patient-centric environments of general hospital and medical centers—and even surgical services and perianesthesia departments—will not...more

New Yorker Cartoon Caption Contest, Origins of Corporate Culture and Compliance

I hope everyone had a great 4th of July. One of the small pleasures I take each week is reading the New Yorker’s Cartoon Caption contest. I have entered most weeks for the past 10 years or so when the spirit moved me with a...more

Financial Services Quarterly Report - Second Quarter 2016: The Hong Kong Professional Investor Regime

Similar to the situation in many other jurisdictions, fund managers, banks and other market participants in Hong Kong were, until recently, not required to apply the same regulations to high net worth, corporate or...more

Dress code banning Muslim headscarf justified?

In the case of Achbita and another v. G4S Secure Solutions NV [2016] CJEU C-157/15, the Advocate General has given her opinion on whether a private employer could prevent a female Muslim employee from wearing a headscarf at...more

Compliance Training, Part I

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

Morgan Stanley Fined $1 Million by SEC for Cybersecurity Violations

The SEC has taken a new enforcement action, demonstrating its expectations of industry and the willingness to use the variety of tools at its disposal to address concerns with cybersecurity previously signaled by an...more

How to Simplify Your Code of Conduct Attestation Language

What does your code of conduct acknowledgement process look like? If your annual attestation language is long, confusing or overly complicated, you run the risk of alienating your employees—and missing an opportunity to...more

165 Results
View per page
Page: of 7
JD Supra Readers' Choice 2016 Awards

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.