Polsinelli Podcast - Conducting Business in China
Is an Honor Vacation Policy Right for My Company?
FCPA Compliance and Ethics Report-Episode 11 with Eddie Cogan
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
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
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
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
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
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
For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more
I’ve been getting more involved with our company’s social media presence lately, which is quite the double-edged sword. On the plus side, my team is very happy, I’m finding loads of great content and wonderful subject matter...more
Readers of this blog know I am huge Civil War buff. Growing up in Texas, I only focused on the Southern side as a youngster and while this led to a sometime myopic view of events, in my mid-20s when I did begin to study the...more
I’ve watched for several years now the supposed controversy regarding the requirement of separating the general counsel and chief compliance officer roles. The arguments against combining the roles have ranged from a single...more
I get it – snooze-worthy, old-fashioned harassment and discrimination training isn’t in line with the vibe you’re trying to create at your hip tech startup. You want to be laid back, cut out all the corporate bull$&^*, build...more
I read an article in EthicsMonitor by Cynthia Schoeman called How to Crack Your Company’s Code of Ethics. Cynthia makes some good points about Codes of Ethics that align with our thinking about what good employee training...more
The now infamous General Motors mea culpa, which followed the automotive giant’s recall of almost six million cars, has brought the importance of a “speak up culture” front and center. As part of the company’s long road to...more
It’s no secret that ethics and compliance professionals struggle with measuring the effectiveness of their programs. Sometimes the “well, we have to do it anyway” mentality can preclude any attempt at real measurement and...more
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
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
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
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
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
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
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
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
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
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
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
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