Code of Conduct

News & Analysis as of

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

Traders and Compliance Professionals Take Note: Phase One of New BIS “Global Code” Establishes “Best Practices” in the Foreign...

Limitations on Use of Confidential Information is Prominent in the New Standards Continuing Recent Enforcement Trend in the Commodities and Derivatives Markets - On May 26, 2016, the Foreign Exchange Working Group...more

NLRB Again Rejects Employer Code of Conduct Provisions Requiring Positive Coworker Relations

Last month, the National Labor Relations Board continued its rejection of employer conduct policies intended to promote harmonious and productive working relationships among employees. In T-Mobile USA, Inc., unionized...more

FCPA Compliance and Ethics Report-Episode 255-revising your Code of Conduct [Video]

In this episode, I discuss the considerations going into the revision of your Code of Conduct and how to move forward to do so. ...more

The SEC, CCOs and Compliance Programs

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Top tips for franchisors entering Australia

The franchising industry is projected to post annualised growth of 2.8 per cent over the next five years according to a recent report by IBIS World – one of the leading industry researchers operating in that market. The...more

NLRB Rejects General Employee Behavior Standards in Code of Conduct

The National Labor Relations Board continues its assault on employer handbooks and other policies it considers to impede employees’ rights to engage in protected concerted activity under Section 7 of the NLRA. Last month, the...more

Work Rules Hanging in the Balance? NLRB Dissenter Proposes Balancing Test Blueprint for Work Rule Challenges, a Significant...

Earlier this month, the NLRB struck down a couple of facially-neutral workplace civility rules in an employer’s Code of Conduct. Ho hum, business as usual. What is fascinating, however, about this otherwise unremarkable...more

Compliance Training and Cat Videos

The following interview is with Ricardo Pellafone, Creative Director & Founder, The Broadcat, www.thebroadcat.com RTB: Tell us a little about your background and current work. RP: I’m an...more

Top Ten Ethics & Compliance Predictions & Recommendations for 2016

To help with our predictions and recommendations, we’ve talked with industry experts, our colleagues at NAVEX Global, and ethics and compliance professionals from our more than 12,500 client organizations. Based on their...more

EU Commission launches consultation on Transparency Register - Stakeholders invited to present views on a future mandatory system...

The European Union is contemplating mandatory registration of lobbyists and increased regulation of their activities through the introduction of a mandatory register in Brussels. The changes currently contemplated will have a...more

Compliance and Mastering Strategy

One thing that is often difficult for Chief Compliance Officers (CCOs) is to look at compliance strategy rather than the tactical aspects of compliance. This is because it is usually the day-to-day aspects of doing compliance...more

UK Financial Regulatory Developments - February 2016 #1

FMLC issues addendum to legal uncertainty for CCPs paper - FMLC and the US-based Committee on Capital Markets Regulation (CCMR) have issued an addendum to their comment paper on issues of legal uncertainty relating to...more

Dazed and Confused: A Look at Medical Marijuana and Ontario Schools

As the Canadian medical marijuana industry continues to expand and evolve at a rapid pace, unintended gaps have begun to appear across a wide spectrum of legislation. One such gap currently exists in the Ontario school system...more

Focusing on Internal Investigations

A speak up culture is an important component of a company’s commitment to organizational justice. All of the pieces of an internal justice system have to fit together and are interdependent. When one part does not work, the...more

2016 Trends #4: Politics Invade the Workplace

In the U.S., the 2016 election now dominates the news, social media and many employee conversations. And for global companies, it’s always election season somewhere. So now is a good time for ethics and compliance officers to...more

St. Mark’s Basilica and Updating Your Code of Conduct

The Venice Travel Edition continues today by focusing on Saint Mark’s Basilica, one of both Venice’s and the world’s treasures. It sits on Saint Mark’s Square, one of the most famous locations in all of Italy. While today it...more

ESMA updates on proxy Code of Conduct

ESMA has published an update report on the proxy advisory industry’s progress in establishing and following a self-regulatory code of conduct. It says there has been progress, but there is room for improvement....more

SFC Published the Consultation Conclusions on the Client Agreement Requirements

On 8 December 2015, the Securities and Futures Commission of Hong Kong (the “SFC”) released the “Consultation Conclusions on the Client Agreement Requirements” (“Consultation Conclusions”), in which the SFC has resolved to...more

Defining Compliance 2.0: Key Compliance Partners (Part 5 of 5)

I always use the “Streetcar Named Desire” line to describe the challenges a  Chief Compliance Officer faces – CCOs depend on the kindness of strangers.  It is a little bit of an exaggeration but bear with me. CCOs are not...more

Defining Compliance 2.0 — The CEO (Part 2 of 5)

Do the right thing. It will gratify some people and astonish the rest. – Mark Twain We all know the obvious – a CEO’s commitment to ethics and compliance is critical to the success of a compliance program. A CEo who...more

Invest Europe publishes new handbook

Invest Europe has published its 2015 Handbook of professional standards and conduct of business for the private equity industry....more

Lobbying: Important amendments to the Lobbyists’ Code of Conduct

On December 1, 2015, a number of amendments to the Lobbyists’ Code of Conduct (the Code) will come into force. The amendments have the potential to alter the ability of certain persons in the private sector to communicate...more

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