Code of Conduct

News & Analysis as of

Creating a Culture of Ethics and Respect: It’s all about Who You Are and Who You Want to Be

Our annual Benchmark Report always provides great insights into what’s on the minds of ethics and compliance officers, and this past year’s was no different. Probably the most interesting result from our 2016 survey was that...more

Putting the "E" in Ethics & Compliance

Developments in information technology are creating more and more opportunities for the automation of E&C programs. Automation and integration can benefit programs in many ways, including increasing effectiveness, efficiency...more

Walking the Walk and Talking the Talk – A CEO’s Commitment to Ethics and Compliance

The phrase tone at the top is becoming trite. Compliance professionals use it over and over, and few people explain how to apply the concept. Speakers and webinar presenters always gloss over tone at the top, emphasizing...more

UK Regulation Round Up - January 2017

Welcome to the UK Regulation Round Up, a regular bulletin highlighting the latest developments in UK regulation for alternative asset managers. The start of 2017 saw a number of regulatory developments including...more

SFC Publishes Circulars and Updates FAQs on the Triggering of, and Compliance with, Suitability Obligations

Key Points - - Clarification and new guidance relating to suitability obligations under the Code of Conduct. - Outlines the regulatory obligations of licensed or registered persons....more

Four Things Compliance Practitioner Should Know About the Eurasian Economic Union

Four Things Compliance Practitioner Should Know About the Eurasian Economic Union - An effective Compliance risk management at emerging markets for any business significantly depends on timeous observation of changes in...more

Title IX Update: January 2017 - Recent Title IX Developments

Nexsen Pruet’s Title IX team assists educational institutions in Title IX compliance. The team’s primary focus includes assisting with Title IX complaint investigations and serving as adjudicators. The team also provides...more

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

"New French Anti-Corruption Legal Framework"

A new French law titled “Transparency, the Fight Against Corruption and Modernization of the Economy,” which was published in the French Official Journal on December 10, 2016 (known as Sapin II, as it was named after the...more

High Court Decision Serves as a Cautionary Tale for Office Holiday Parties

The High Court ruled on December 1, 2016 that Northampton Recruitment Limited was not liable when a manager punched an employee twice in the head after a Christmas party. While the Company was not held liable, the case is a...more

Compliance Role in Mitigating Cyber Mayhem

In recent years, attention has been drawn to the impact of cyber and data breaches and the extent to which our organizations remain vulnerable to these threats. The cost of cyber and data security breaches is well known and...more

The Baker Hughes GeoMarket Ethics and Compliance Committee

Two of the most common compliance focused committees for public companies are those at the Board level and those which sit between the Chief Compliance Officer (“CCO”) and the Board, usually consisting of very senior...more

Code of Conduct Training – Now What?

When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of...more

The SEC’s Continuing Refinement of Internal Controls Enforcement

My good friend and colleague, Tom Fox, has written an interesting post on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement...more

Shock the Monkey: Police Officer Photo Post on Social Media Costs Him His Job

When is a “joke” so not funny that you lose your job? The Mississippi Court of Appeals gave some direction on that question, affirming the City of Meridian’s termination of a police officer for an inappropriate (arguably...more

The Chairman’s Flight and the US Corrupt Practices Act

Earlier this week a most interesting non-Foreign Corrupt Practices Act (FCPA) bribery and corruption enforcement, actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit...more

Doing the Two-Step: Prioritizing Risks and Allocating Resources

Chief compliance officers face imposing tasks on a daily basis. The tasks often look insurmountable and it is easy for CCOs to just turn away and find a more manageable set of tasks....more

Code of Conduct: Your Corporate Constitution

How important is your company’s code of conduct? We liken it to a corporate constitution—your highest-level policy, from which all of your other policies, procedures and rules derive, and without which you cannot expect to...more

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

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