Corporate Culture

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Spud Webb and Corporate Culture

On this day 30 years ago, history was made when Spud Webb won the 3rd NBA Slam Dunk contest. Webb joined future Hall-of-Famers Michael Jordan, who won the inaugural contest in 1984, and Dominic Wilkins, who won the second...more

What Good Compliance Looks Like: Part III

I concluded Part II of “What Good Compliance Looks Like” with “compliance and tone at the top are more than stated values, it’s about operational and unspoken values. It’s about a seat at the table of business strategy.”...more

What Good Compliance Looks Like: Part II

In a prior post, I shared the view of a CEO of a Fortune 500 company, who launched his talk at a compliance event by asking “what does good look like?” In that post, I concluded with how “I spent the better part of my career...more

Business Success: How to Establish a Winning Company Culture

True business leaders are good at what they do — they are skillful planners, have passion for what they do and exercise good judgment. At a recent Seattle seminar for startup companies, I stressed that “company culture”...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

SEC’s First Whistleblower Award to Company Outsider: Game Changer?

The headlines lit up this month when the Securities and Exchange Commission (SEC) issued its first-ever award to a whistleblower who wasn’t employed by the company on which he had blown the whistle. The award was a...more

2016 Trends #6: Working With HR—Time to Try Again

It’s been said that no corporate function has the opportunity to contact more employees more often than Human Resources. Recruiting, hiring, on-boarding, performance reviews, promotions, investigations, discipline,...more

How the Venetian Gondolier Informs Your Compliance Program

This is my final Travel Edition from Venice. If there is one thing that is ubiquitous throughout this city it is the Gondolier, the Venetian Gondola boatman. You are never far from hearing their cry of “Gondola, Gondola” to...more

FINRA Releases 2016 Regulatory and Examination Priorities Letter

On Jan. 5, 2016, the Financial Industry Regulatory Authority (“FINRA”) issued its annual Regulatory and Examination Priorities Letter (“2016 Examination Letter” or “Letter”), along with a press release from FINRA chairman and...more

Ways to Boost Employee Morale

Often times the day-to-day issues that human resource professionals encounter with employees are not necessarily the legal “can we or can’t we” types of issues but, rather, are related to employees’ interactions with one...more

FINRA’s 2016 Focus - Proactive Compliance in Innovative Market

On January 5, 2016 FINRA released its annual Regulatory and Examination Priorities Letter identifying its 2016 areas of focus, as well as areas of historical focus. FINRA identified three priority focus areas for 2016: (1)...more

FINRA’s 2016 Priorities: Fives on the Fifth

FINRA released its annual Regulatory and Examination Priorities Letter (so-called “Errico Letter”) on January 5. FINRA’s top five priorities: Among the also-rans, industry participants will recognize many perennial favorites,...more

What Does Good Compliance Look Like?

At a corporate summit, the CEO of a Fortune 500 company started his talk by asking “what does good look like?” Good question. “Rules often inspire legalism and minimalism,” he said. “But they don’t govern behavior.” He...more

Business Succession Planning - January 2016

The transition of a family owned or closely-held business involves a variety of legal and tax issues. This goals of this process, however, should be focused on issues that are just as important – if not more important – than...more

FINRA’s 2016 Examination Priorities Identifies New Initiatives on Market Integrity and Firm Culture and Further Concern on...

The recently issued 2016 Regulatory and Examination Priorities Letter discloses FINRA’s new initiatives on market integrity and firm culture and reflects a focus on firms’ supervision regarding conflicts of interest and...more

Defining Business Ethics

One of the more frustrating topics for discussion is defining business ethics. It is frustrating to see how complex and unhelpful the discussion turns when defining business ethics. I have two tests for how to deal...more

The Person (Idea) of the Year – Corporate Ethics and Culture

Each year I have identified the so-called “person” of the year to capture the most significant enforcement and compliance trend. In the past, I have given the award to the Chief Compliance Officer, the Ethics Officer, the...more

Ethics and Compliance Predictions for 2016

The New Year brings new promise for compliance professionals. I always sympathize with compliance officers because of their inevitable conflict – their idealism often is confronted by corporate realities – a CEO who...more

Color Blind Cinematography and Making Room for Differences in Compliance

Haskell Wexler died on Sunday. For those remotely familiar with cinematography or movie-making in general, he was a true giant. According to his New York Times (NYT) obituary, Wexler won two Academy Awards and had a star on...more

Ethics Across the Generations

In the latest edition of Business Compliance, guest author Guendalina Donde (Researcher at the Institute of Business Ethics) writes about “Business Ethics Across Generations: Bridging the Gap.” In her work, Ms. Donde breaks...more

Four Compliance Trends and Challenges for 2016

As we close out the year, it is now time to begin the retrospective reviews and predictions for the New Year. I will try to keep them to a minimum but I find it important to reflect and look forward to new challenges....more

U.K. Procurement Managers to Vendors: Take Cyber Security Seriously or You’re Out

The headlines about massive cyber-security breaches just keep coming these days. Corporate giants Vodaphone, Home Depot, Talk Talk and JP Morgan Chase have all been hacked—to and they're far from the only ones.. But the...more

Star Wars Week Part V – Mistakes of the Galactic Empire (and VW)

Today, we conclude our week long exploration of the original Star Wars trilogy, all posted in conjunction with three podcasts, subtitled May The Podcast Be With You, where we use one movie as a staring point to review Foreign...more

Enforcement Update – DOJ Raises Focus on Prosecuting Individuals

There has been a change in the US Department of Justice regarding corporate disclosures. The recently updated United States Attorney’s Manual has revised its provisions called the “Principles of Federal Prosecution of...more

Organizational Justice: The Importance of Transparency

You know a company’s culture is suffering when you hear the CEO or senior executives say the best way to develop a “Speak Up” culture is to just tell all the employees “we want to hear from you.” I am an advocate for...more

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