Corporate Culture

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Research Shows That Business Ethics Training Can Impact Shareholder Value

Let’s get down to business, or should I say business ethics training. It’s been at the forefront of my mind recently, and not only because I work for a governance, risk and compliance company. I’ve seen so many articles in...more

Promoting Company Culture: Harnessing Happiness or Discriminating on the Basis of Religion?

Does an employer discriminate against employees when it requires them to participate in corporate wellness programs? The Equal Employment Opportunity Commission has taken the position that it does if the wellness program...more

FinCEN Issues Advisory to U.S. Financial Institutions Regarding Promotion of a Culture of Compliance

The Financial Crimes Enforcement Network (“FinCEN”) issued an advisory (the “Advisory”) to U.S. financial institutions (“FIs”, and each an “FI”) in which FinCEN highlights “the importance of a strong culture of [Bank Secrecy...more

Creating a Culture of Ethics and Compliance [Video]

An effective compliance program requires a culture of ethics and compliance, including "tone-at-the-top." A company's culture is not easy to measure. Nonetheless, there are practical steps which can be implemented to collect...more

Bridging the Workplace Creativity Gap

Progressive employers want workers with high levels of what David Kelley calls, in his recent book of the same title, “Creative Confidence.” Kelley, the head of Stanford’s d.school and founder of the design firm IDEO, defines...more

Culture of Compliance: FinCEN's View

I have been promoting the concept of a Culture of Compliance (“Compliance Culture”) for some time. Indeed, I have written rather extensively about it and lectured on the subject. As recently as February 2014, I published a...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM [Video]

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Five Most Common Weaknesses in Anti-Corruption Compliance Programs

In this Internet-age of ADHD and simplistic thinking, I thought I would contribute this week by putting together some lists of common themes in the ethics and compliance world. Unfortunately, we are all addicted to quick...more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Complaints to Investigations to a Speak Up Culture: Maintaining Important Connections

Like Tinkers to Evers to Chance completing a double play, compliance programs need to maintain important links among three key elements – its complaint system, the handling of such complaints, and the publicized resolution of...more

Bankers Swear To An Ethics Oath; Have They Sworn to Take Ethics and Compliance Training?

My mother enrolled me in Girl Scout Daisies when I was six. It’s an all-girl organization that seeks to help out the community and give back to those less fortunate, and is basically the precursor to becoming a Girl Scout...more

Shuffleboard, Early Bird Specials, and . . . Whistleblowing?

When most employers hear the word “whistleblower,” they think of their current employees and various anti-retaliation laws; however, under the SEC’s “Whistleblower Program,” the “whistleblower” may be a current or former...more

Practitioners Share Their Top Ethics & Compliance Training Objective -- And It's Not What You Might Expect

Ninety percent of survey respondents from NAVEX Global's 2014 Ethics & Compliance Training Benchmark Report, cited their top ethics and compliance training objective as “Create a culture of ethics and respect.” This was...more

A Conference on Law and Corporate Social Responsibility

International Bar Association Conference on Law and Corporate Social ResponsibilityIt used to be that the links between corporate social responsibility (“CSR”) and the law were not so clear. Practitioners in the field were...more

Four Important Steps to Promote A Speak Up Culture

Companies spend a lot of time and effort promoting a “Speak Up” culture. Even before the SEC’s whistleblower program, senior managers recognized that they needed to know what is occurring in the company. The only way to learn...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part III

So, now you’re ready to start your culture audit… Some key questions you want to ask before you start are: Do I have the support of Executive leadership? If not, go back to your E&C steering committee and work through...more

Rationalizing Bribery: Corruption Has No Witness.

This is part three of my four part series on how I "Rationalized Bribery." It addresses the reality that there are usually no witnesses to overseas discussions involving an actual or potentially corrupt transaction....more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part II

This one is tough, especially in global organizations. In many countries, you simply cannot run a background check, as criminal records are not public. In others, you can run them, but the criminal offense must be related to...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part I

We’ve talked a lot in our Tales from the Crypt about the signs to watch for that indicate something’s gone wrong, from minor cultural twists to lapses of integrity that are tantamount to criminal activity. We all wish we had...more

Do you have a whistleblower culture? You should!

Every organization should strive for honesty amongst its employees and stakeholders. This element allows for complete dedication to the organization's mission, and success. Encouraging a whistleblowing culture within the...more

Comprehensive Anti-Bribery Program

If your operations are global, implementing a comprehensive anti-bribery program is likely one of your top priorities. Given the complexity and diversity of the activities that must be addressed in an anti-bribery program,...more

Whistleblowers are important | Ensure yours understand their benefit

Over the last few years, we've seen how the power of whistleblowers can effect change, hold companies accountable and stop corruption. The spotlight on the critical role they could have played is seen in the absence of them...more

Code of Ethics | Code of Conduct - What's the Difference?

The terms "Code of Ethics" and "Code of Conduct" are often mistakenly used interchangeably. They are, in fact, two unique documents. Codes of ethics, which govern decision-making, and codes of conduct, which govern...more

Employee Culture Surveys: Low-Cost Critical Information

It is always amazing to me how reluctant people are to ask direct questions. Interviewers freeze up when they have to ask the big question – “Did you steal the money?” Boyfriends are afraid to ask a girlfriend, “What is the...more

Battling Your GRC Demons: Solving The Top 5 Concerns of Compliance Professionals

Organizations face mounting pressure to deal with their ethics and compliance infrastructures. Increased scrutiny, global regulations, enforcement actions, and the reputational need to be viewed as a company driven by ethical...more

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