Corporate Culture

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CCO Challenges in the Healthcare Industry

Chief Compliance Officers have a tough job. It does not matter what industry they are working in, CCOs face a myriad of challenges. The healthcare industry, however, has its own set of challenges. While there has been...more

Does Your Compliance Training Inspire Employees to Follow Rules or Follow Values?

I read an article in the Wall Street Journal wherein Michael McMillan, director of ethics and professional standards at the CFA Institute, was interviewed and discussed the difference between following the rules and behaving...more

The Danger of Retaliating Against Whistleblowers

Every company claims that they encourage a “speak up” culture. As part of a “speak up” culture, companies encourage managers and employees to raise concerns about potential violations and promise not to retaliate against...more

Gettysburg Day 2 – A Failure of Culture in Leadership and How to Overcome It

Today is the 151st anniversary of Day 2 of the Battle of Gettysburg. Last year I focused on Union General Dan Sickles and how is disobeying of his commanding officer’s order, destroyed his brigade and ended his military...more

An Event That Changed the World and Fostering Compliance Leadership – Part II

Yesterday, I used the assassination of Archduke Ferdinand and its continuing legacy even up until today to introduce a two-part series about ‘Blue Ocean Leadership’. The assassination and some of its legacies were detailed in...more

Three Ethics & Compliance Program Insights You Can’t Afford to Miss

In the first half of this year, I interviewed and conducted focus groups with hundreds of line employees, professionals and managers on four continents and—regardless of country, culture or industry—three themes came up again...more

SEC Chair White Discusses Directors’ Responsibilities

In a recent speech at the Stanford Directors’ College, SEC Chair Mary Jo White discussed several “things that directors should know about the SEC.” Her speech focused on directors as gatekeepers, self-reporting of wrongdoing,...more

Who Owns Business Ethics Training and Code of Conduct: The Divide Between HR & Ethics and Compliance

The title of this blog caught my eye; I just finished reading it and knew you’d enjoy it. “Ethics and the HR department – a Happy Marriage?” by Polly Foley, senior researcher at the Institute of Business Ethics, is about of...more

Drawing the Line on Accountability

With all the attention on ethics and compliance, it is interesting to take account of the vocabulary — terms like “culture, governance, access, processes, diligence, independence, and empowerment” are all bandied about. One...more

Fixing a Company’s Ethics and Compliance Culture

We all have been following the “turn around” projects at some of the big companies — Walmart, Morgan Stanley, SNC-Lavalin, just to name a few. Changing a corporate culture, even under the Sword of Damocles, can be a...more

7 Psychological Insights That Will Increase the Effectiveness of Your Code of Ethics Training

The Free-Rider Problem occurs when people perceive their actions to have a limited impact. From an ethics and compliance standpoint this could be something like insider trading. Consider for a minute that you work for a large...more

Employee-Driven Policy Management: Involving Employees in Policy Creation

It is a known psychological observation that when people are involved in creating something, they get emotionally attached to it. Think of the passion that an artist has for her work. The artist puts in hours, sweat and lots...more

Code of Ethics Training is Worth it! Five Measurable Components of Corporate Culture

This may be my final post-Compliance Week update – I haven’t decided yet. But I’m excited to share thoughts about another session that had some great ideas and discussion. It was about the notion of measuring corporate...more

Hear it From Employees First: Why Managers Should Encourage Whistleblowers

“I have never understood why hospital managers don't crawl, on bended knee, from one end of their trust to the other, begging staff to tell them what's going on, what's wrong and what needs fixing,” says Roy Lilley, former UK...more

Focusing on the Critical Compliance Disconnect

Sometimes Chief Ethics and Compliance Officers need to zero in on an issue because it is critical to the operation of an ethics and compliance program. I am not suggesting that CECOs should never focus on an issue but I am...more

The “Coffee and Naps” School of Business Ethics Training: Part 3

There are a number of pieces that come together to make an end-to-end business ethics training system. The emphasis in that sentence was on system – a successful ethics program isn’t just a one-time event. Let’s look at the...more

Aligning Goals, Resources, and People for Successful Change: An Interview With Tom Robertson, Ph.D.

If you are contemplating organizational change and desire sustained, positive results, there are many factors to consider and steps to take. This post focuses on the concept of alignment. Over the years, Thomas V. (“Tom”)...more

Failure to Plan is Planning to Fail: Keys To Raising Employee Awareness of Ethics & Compliance Programs

Between sessions at last week’s Practicing Law Institute conference in New York, I had several conversations with compliance officers about their ethics and compliance program challenges. The common theme among the challenges...more

Compliance with a Purpose

Chief compliance officers are under intense pressure. They are being watched inside every company to make sure they deliver on their “compliance” program, and outside observers are ready to comment on any misstep or...more

Corporate Culture – The Foundation of Compliance

The bedrock of a compliance program is corporate culture. Let’s all agree to throw away the following often-repeated phrases: ”tone-at-the-top” and “buzz at the bottom.” I would argue that we replace those trite and...more

Finding Your Organization’s Second Wind: An Interview with Consultant Kent Layden

Kent Layden is a principal at Second Wind Consulting, LLC. In his more than 30 years of practice, he has conducted over 300 organizational development projects for corporations, governments, and non-profits to improve...more

The “Coffee and Naps” School of Business Ethics Training: Part 2

In Part One of this series, we discussed how to complete an ethics audit and culture snapshot. Today we’re going to explore the importance of your relationship with your CEO (or Chief Culture Officer) in building an ethical...more

Why Not Use Ethics Training as a Feedback Mechanism to Improve Culture?

I read this great blog by Ken Reda on the Profit Advisory Group site. The blog “Is Your Company Culture Costing You Money?” is fascinating. Those of you who regularly read my blogs (thanks!) know I’m all about company...more

Essential Requirements For An “Effective” Ethics and Compliance Program

A client recently reminded me – “Mike, it is not just an ethics and compliance program, it is an “effective ethics and compliance program.” I always learn from my clients and this was an important reminder for me – focus on...more

Best Practices in Employee Engagement: Interview of TIAA-CREF’s Head of Organizational Effectiveness

TIAA-CREF, a financial services company with over $500 billion in assets under management, has made employee engagement a priority. Its Head of Organizational Effectiveness, Josh Greenwald, agreed to share what his company...more

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