Corporate Culture

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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

Code of Conduct, Compliance Policies and Procedures-Part I

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

Nature Or Nurture? Use Code of Ethics Training, Annual Culture Assessments to Nurture Ethical Culture

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

John Bell Hood and the Measurement of Conduct Risk

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

Fauxtroversy: Combining or Separating GC and CCO Roles?

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

3 Reasons Why Tech Startups Struggle with Discrimination and Harassment Training (And 5 Effortless Ways to Protect Your Startup)

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

5 Elements Your Code Of Ethics Training Should Address

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

Speak Up or Pay Up: Lessons from GM

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

3 Questions To Help Develop Ethics and Compliance KPIs (Beyond Business Ethics Training Scores and Whistleblower Hotline Calls)

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

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

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