News & Analysis as of

Compliance Department of Justice (DOJ) Code of Conduct

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Society of Corporate Compliance and Ethics...

How a code of conduct reflects culture and meets DOJ requirements

Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more

Thomas Fox - Compliance Evangelist

Your Code of Conduct

What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action as proof of ethical overall behavior....more

Thomas Fox - Compliance Evangelist

The Power of Compensation: Building a Culture of Compliance

The Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have repeatedly emphasized the importance of aligning compensation plans with compliance goals. According to Tom Fox, aligning the compensation...more

HaystackID

Compliance Programs Under the FCPA: Ways to Minimize Liability for Payments to Foreign Officials

HaystackID on

Background Note: In their analysis of the Foreign Corrupt Practices Act (FCPA), Adam Rouse, Vazantha Meyers, and Ashish Prasad emphasize the crucial role of robust compliance programs in minimizing liability associated with...more

Thomas Fox - Compliance Evangelist

J&F – The SEC Order

Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

From the Code of Conduct to Risk Assessment to Continuous Improvement

How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more

Thomas Fox - Compliance Evangelist

A Tribute to Bill Yeoman: Compliance Metrics For a Board

Bill Yeoman died this week. You have to be a knowledgeable fan of college football to recognize that name as he retired in 1986. He was the head coach for the University of Houston (UH) Cougars for 25 years. His contributions...more

Thomas Fox - Compliance Evangelist

Creating an Inventory of Metrics

I recently had the opportunity to visit with Michele Edwards, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more

Thomas Fox - Compliance Evangelist

Arthurian Week: Part 1 – The Pentecostal Oath and Code of Conduct

What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in...more

Health Care Compliance Association (HCCA)

[Webinar] Designing and Implementing a Health Care Code of Conduct under OIG and Department of Justice Guidance - April 28th,...

This presentation is for ethics and compliance professionals in the health care industry. Main Points Covered: Learn how to: Reflect industry standards, organizational culture, mission and values in your Code Build...more

Perkins Coie

“See Something, Say Something”: Prompt Reporting of Criminal Antitrust Violations Is Critical

Perkins Coie on

When the DOJ is deciding whether to charge a company with a criminal antitrust violation, or agreeing to a deferred prosecution agreement (DPA), the effectiveness of a company’s antitrust compliance program is only one...more

Thomas Fox - Compliance Evangelist

Farewell to Rip Torn and Hello to Compliance Incentives

In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...more

The Volkov Law Group

Ethics and Culture Lessons from the NBA Finals

The Volkov Law Group on

Many organizations struggle with their internal culture for a variety of reasons.  Establishing a strong and compliant corporate culture is paramount for an effective compliance program, as even the DOJ has harped on in its...more

The Volkov Law Group

The Real Focus for Compliance: Post-Acquisition Integration of an Acquired Company (Part III of III)

The Volkov Law Group on

In light of the evolving (or evolved) DOJ and SEC approach to FCPA enforcement in the merger and acquisition context, global companies have to emphasize their post-acquisition process. ...more

Thomas Fox - Compliance Evangelist

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more

Thomas Fox - Compliance Evangelist

Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine

Procedural fairness is one of the things that will bring credibility to your Compliance Program. Today it is called the Fair Process Doctrine and this Doctrine generally recognizes that there are fair procedures, not...more

Thomas Fox - Compliance Evangelist

Code of Conduct Week: Part V – Operationalization

I have reviewed the creation and update of a Code of Conduct this week, with a big assist from Eric Morehead, the Principal of Morehead Compliance Consulting. We reviewed the legal requirements, the suggested structure and...more

NAVEX

CCOs Say Policies Are Getting Stronger; Adoption of Technology – Not So Much

NAVEX on

KPMG recently published its latest survey of chief compliance officers. The report highlights the increasing value of effective Compliance. It also reveals growing pains of our industry, specifically in maximizing...more

Thomas Fox - Compliance Evangelist

Code of Conduct Week: Part IV – Training on Your Code of Conduct

Today focus in the Code of Conduct series is on the aspect of training on your finalized Code of Conduct. Eric Morehead, Principal of Morehead Compliance Consulting, joins me in this series. While there have been criticisms...more

Thomas Fox - Compliance Evangelist

Code of Conduct Week: Part I – Introduction

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

Thomas Fox - Compliance Evangelist

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

Thomas Fox - Compliance Evangelist

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

Thomas Fox - Compliance Evangelist

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

Thomas Fox - Compliance Evangelist

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

Thomas Fox - Compliance Evangelist

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

35 Results
 / 
View per page
Page: of 2

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