News & Analysis as of

Discipline Department of Justice (DOJ)

Thomas Fox - Compliance Evangelist

Farewell to The Hawk – Fair and Consistent Application of Discipline

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Thomas Fox - Compliance Evangelist

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Thomas Fox - Compliance Evangelist

Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine

Procedural fairness is one of the things that will bring credibility to your Compliance Program. Today it is called the Fair Process Doctrine and this Doctrine generally recognizes that there are fair procedures, not...more

NAVEX

New Guidance from the DOJ on Your Compliance Program

NAVEX on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

Franczek P.C.

Department of Education Releases New Guidance on SROs, Police in Schools

Franczek P.C. on

The Department of Education (DOE) and the Department of Justice (DOJ) have issued non-binding regulatory guidance regarding law-enforcement officers’ involvement in the administration of school discipline. The new guidance,...more

Thomas Fox - Compliance Evangelist

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Parker Poe Adams & Bernstein LLP

Employees Using FMLA Leave Must Abide by Employer's Absence Notification System

Intermittent leave continues to pose some of the most vexing Family and Medical Leave Act problems for employers. Employees eligible for intermittent FMLA leave frequently miss work without advance notice, leaving the...more

Thomas Fox - Compliance Evangelist

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

Pullman & Comley - School Law

Dear Colleague Letter Urges Districts to Abandon “Zero Tolerance” in Student Discipline Policies

The Office for Civil Rights of the U.S. Department of Education (OCR) and the Civil Rights Division of the Department of Justice recently released a joint “Dear Colleague Letter” (DCL) providing guidance on administering...more

The Volkov Law Group

Three Keys To An Effective Disciplinary Program

The Volkov Law Group on

The Justice Department and the SEC have underscored the importance of a company maintaining a clear disciplinary process so that executives, managers and employees are aware that a violation of the corporate code of conduct...more

Best Best & Krieger LLP

Federal Authorities Crack Down on Student Discipline Practices

U.S. Departments of Education and Justice Issue Guidance Warning Against Unlawful Discrimination in Student Discipline - U.S. Secretary of Education Arne Duncan and U.S. Attorney General Eric Holder this week issued a...more

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