Code of Conduct

News & Analysis as of

KBR And Maintaining Privilege Throughout Investigations

Last month, for the second time, the D.C. Circuit in In re Kellogg Brown & Root Inc., No. 14-5319, slip op. (D.C. Cir. Aug. 11, 2015), granted a writ of mandamus sought by KBR and vacated a series of district court orders...more

The Dalton Gang’s Last Stand and What is a Conflict of Interest?

On this day in 1982, the fabled Dalton Gang rode into Coffeyville, Kansas, supremely confident in its ability to simultaneously rob two banks in the town. When the dust settled, four of the five gang members lay dead. The...more

Why Getting Handbooks Right Matters: NLRB Judge Holds Verizon’s Restrictions on Employee Communications During Non-Working Time...

Despite previous NLRB rulings telling them to stop, some employers continue to impose broad prohibitions on personal employee communications over company email. As an administrative law judge recently reminded us, failing to...more

The New EU Benchmark Regulation

There has been increased pressure on the EU to restore confidence in the integrity and accuracy of benchmarks following the LIBOR and EURIBOR market-rigging scandals. Multi-million Euro fines have already been levied against...more

Volkswagen Emissions Scandal Speaks to Troubled Culture

Too many organizations learn the hard way that failure to create a speak-up culture poses risks that go far beyond financial calamity. Volkswagen (VW) appears likely joining those sad ranks today, as it scrambles to figure...more

In Canada, Foreign Workers Seek to Use International Norms as the Standard of Care in Negligence Claims Against Multinationals...

Non-Canadian workers are increasingly suing their employers in Canadian courts for human rights violations allegedly committed outside Canada by the companies themselves or by other entities in their supply chains. This...more

Health Alert (Australia) - September 14, 2015

In This Issue: -Judgments; Legislation; and Reports -Excerpt from Judgments New South Wales (NSW) 9 September 2015 - Idameneo (No 123) Pty Ltd v Auzcare Pty Ltd [2015] NSWSC...more

Financial Regulatory Developments Focus - September 2015 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Leveling the Playing Field: Mobile Location Analytics

As brick-and-mortar retailers face increasing challenges to compete with their online counterparts, a new tool is helping to level the playing field: mobile location analytics. Traditionally, online retailers have had an...more

Highway 61 Revisited Week – Ballad of a Thin Man: Fair Process and Setting Expectations in Your Compliance Program

The Ballad of the Thin Man revolves around one very square man who keeps blundering into situations that he does not understand. The further he gets into the song, the less he seems to understand. Rock critic Andy Gill has...more

PSR welcomes code of conduct for indirect access providers

PSR has welcomed the voluntary code of conduct for indirect access providers, published by trade group Payments UK. The code sets out standards of best practice for key elements of the commercial arrangements between indirect...more

Ready to Revolutionize Your Code of Conduct Experience?

As you may know, we have recently launched our new Agile Code of ConductTM. It’s a Web-based Code of Conduct that uses the Web to give employees the information and guidance they need. It kind of moves your Code from a static...more

Our Picks for the August Top 10 Ethics and Compliance Articles You Don’t Want to Miss

With so many articles available every month, it’s possible that a few got buried in either your inbox or the depths of the blogosphere. But for professional growth (and a quick break from the daily grind), we all know it’s...more

Internet of Things Framework introduced by the Online Trust Alliance for our connected world

On August 11, 2015, the Online Trust Alliance (OTA) released an Internet of Things (IoT) Trust Framework (“the Framework”), which presents guidelines for IoT manufacturers, developers, and retailers. The Framework was...more

The NLRB Expands Its Reach in the Non-Union Workplace

The National Labor Relations Board continues to infiltrate the workplace even where there are no unions. Standard workplace policies — including those relating to employee conduct, protecting intellectual property, use of...more

What Is Your Case Management Missing? A Look at the Key Functions You Should Expect from Your Case Management Process

We all know how important a Case Management solution is when it comes to collecting and managing incident reports throughout your organization. Not only does it provide you with deeper insights into your employees behavior,...more

SEC- BNY Mellon Settle FCPA Charges Tied To Hiring Relatives of Officials

The SEC has been investigating sovereign wealth funds and issues relating to the hiring of friends and family of foreign officials for some time. Now it has filed a settled action centered on both of those issues which...more

New Risks - the New Senior Manager and Senior Insurance Manager Regimes

From 7th March 2016 (and 1st January for insurers), a new regulatory financial services regime will be in place in the United Kingdom. The new regime is significant; it is intended to make it far easier for UK regulators; the...more

Creating an Engaging Global Code of Ethics: Transcending Cultural Differences

Creating an engaging Code of Ethics can be tricky in your home country – creating a global code that transcends cultural differences is no easy task. Unfortunately, far too many companies brush off its importance. In this...more

D.C. Circuit Upholds Attorney-Client Privilege Again in In re Kellogg Brown & Root, Inc.

On August 11, 2015, the U.S. Court of Appeals for the D.C. Circuit granted a petition by Kellogg Brown & Root, Inc. (“KBR”) for a writ of mandamus in order to protect KBR’s assertion of attorney-client privilege over its...more

July Whistleblower Digest | News Your CCO Needs to Know

This month’s digest features whistleblower collections for a corporate insider who helped solve a fraud case and for five individuals who uncovered a False Claims Act violation. This digest also features a section of news...more

Social Media Week Part II – Sharing in the Compliance Function

I continue my exploration of the use of social media as a tool of doing compliance by looking at some concepts around the sharing of information. In a recent podcast on Social Media Examiner, entitled “Sharing: The Art and...more

The Fingerprint File Doesn’t Have to Bring You Down: NAI Offers Advertisers Guidance on Digital Fingerprinting & Location...

Advertisers who use tools such as location data and newer non-cookie technologies to deliver interest-based advertising must carefully balance the use of those tools with consumer privacy. To achieve this balance, the Network...more

Social Media Week Part I – Using Social Media In Your Compliance Program

Welcome to Part I of Social Media Week. I recently did a webinar, hosted by The Network, on the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program. The response was as great as almost any...more

Retail Tracking Update: Privacy Guidance Following Nomi Technologies

There is currently a widespread effort to quantify everything, from steps, to sleep, to batted ball exit velocity. Fifteen years ago, TV host Jeremy Clarkson tested an innovative new supercar that could quantify your driving...more

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