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Ethics

SCCE Wrap Up – Final Reflections on CEI 2017

by Thomas Fox on

The 2017 SCCE Compliance and Ethics Institute (CEI) is now in the books. Once again, the organization had record setting attendance with over 1,800 attendees from some 41 different countries. During the event, I had the...more

The Ethics Advisor: Fair Elections in California

by Best Best & Krieger LLP on

I can hear my suegros now, if they were alive, asking, “¿Qué es un ‘bot’?” if they were subjected to the frequent stories on the nightly news about Russian meddling in our national elections. Who knew even a few years ago...more

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

SCCE Preconference Learning – You Are Not Alone in Compliance

by Thomas Fox on

I am writing this today from the Society of Corporate Compliance and Ethics (SCCE) 2017 Compliance and Ethics Institute (CEI). This is the largest annual gathering of compliance professionals anywhere and it is already off to...more

CA State Campaign Ads To Require Greater Disclosure of Funding; Cities & Counties Could Go Deeper

by Nossaman LLP on

The California DISCLOSE Act (Assembly Bill 249), was signed into law on October 7, 2017. It overhauls portions of California’s Political Reform Act (“PRA”) that require disclosure of certain campaign finance activity and...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

HSBC’s making good on its plans to shift to a focus on Asia by naming John Flint—who spent his first 14 years at the bank in Asia—as its new CEO. Flint will take over from Stuart Gulliver in February....more

Lawyers Can Be A Positive Force for Compliance

by Michael Volkov on

Lawyers get a bad rap, and I am not just referring to all the lawyer jokes we have heard numerous times. Lawyers get a bad rap when it comes to compliance. Much of it is not deserved – but candidly, some of it is deserved....more

For the Benefit of Mr. Kite – Fiction in the World of Quality Assurance

by Thomas Fox on

The basics were laid out by Peter Wells and Emiko Terazono in a Financial Times (FT) article entitled “Kobe Steel scandal hits Boeing, Toyota and Nissan”. The Japanese company admitted it had falsified “inspection data on an...more

In Defense of Compliance Checklists

by Michael Volkov on

Compliance officers have to avoid complicating a compliance program. As in many areas in life, there is a value in simplicity. Take for example a compliance training presentation. If a compliance officer overwhelms his/her...more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 3

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

The Importance of A Robust Conflicts of Interest Program

by Michael Volkov on

It is always interesting to learn how companies handle specific compliance issues. Years ago, I could always tell when a compliance department was lacking in stature and independence in a company. Typically, I observed three...more

Farewell to The Hawk – Fair and Consistent Application of Discipline

by Thomas Fox on

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

Compliance Meaningfulness: Hard to Achieve, Easy to Destroy

by NAVEX Global on

This post originally appeared on the Richard Bistrong, Front-Line Anti-Bribery Blog, www.richardbistrong.com and is reposted with the permission of Richard Bistrong. In an article titled, What Makes Work Meaningful- Or...more

Steering the course – navigating bribery and corruption risk in private equity investments: Part 1

by Hogan Lovells on

Identifying Bribery and Corruption risk in the context of private equity investments (and M&A more generally) is key to ensuring the value of an acquisition. Companies will busy themselves with due diligence on tax,...more

The Delusion of a Bare-Bones Compliance Program

by Michael Volkov on

Instead of wrestling over the definition of an “effective” ethics and compliance program, let’s take a step back and define what we all agree on is an “ineffective” compliance program. Unfortunately, when you work in the real...more

It’s A Slam Dunk: Take Steps Now To Avoid Tough Lessons Learned By Several NCAA Basketball Programs

The recent indictment of at least 10 individuals associated with college basketball should alert every university, and many businesses, to the importance of operating strong ethics and compliance programs and conducting...more

What a CCO Can Learn from Da Vinci

by Thomas Fox on

When Walter Isaacson publishes a book, you would do well to read it. His previous books have included biographies of such disparate luminaries as Steve Jobs, Albert Einstein, Henry Kissinger and Benjamin Franklin. My personal...more

Day 20: What Does Innovation in Compliance Look Like?

by Thomas Fox on

As I end this section on innovation, I want to conclude by laying out a road map which allows a CCO or compliance practitioner to make more effective and better operationalize a corporate compliance program. With the DOJ’s...more

The Five Most Important Issues for a CCO to Report to the Board

by Michael Volkov on

Chief compliance officers have to throw out their template for charts, diagrams and data that they use to report to the Audit/Compliance Committee and start over. Slick and colorful charts and diagrams are great but CCOs are...more

Perspectives for the Professions Newsletter - September 2017: Importance of Clear Guidelines and Policies

by Field Law on

Silwin v College of Physicians and Surgeons, 2017 ONSC 1947, upholding a Discipline Committee’s decision to reject a defence of officially induced error on the basis that the professional unreasonably misinterpreted the...more

Ethics and Compliance Controls – Different Means to the Same Objective

by Michael Volkov on

People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically...more

Compliance Training Lessons From Utah, Caught on Tape

by NAVEX Global on

For a while now, I’ve been contemplating ethics and compliance lessons from the arrest of Alex Wubbels— the Utah nurse taken into custody by Salt Lake City police, because she refused to draw blood for an unconscious patient....more

CEO Leadership – Honesty, Integrity, Listening and Empathy

by Michael Volkov on

At the outset, let me concede that I am not a psychiatrist (although we all feel like one at times with family members and colleagues). My observations on CEO leadership come from my own life experiences, and professional...more

Significant Changes In Anti-Bribery Laws In Mexico And Colombia Signal A New Commitment To Anti-Corruption Efforts

by Morgan Lewis on

For companies with global operations, the Foreign Corrupt Practices Act (FCPA) is no longer the only anticorruption law of significance. Mexico and Colombia recently enacted sweeping anti-corruption legislation aimed at...more

Behavioral Ethics & Just-in-Time Compliance Communications

by NAVEX Global on

Timing is everything. At least, that is part of the learning from several experiments described in a Harvard Business School Working Paper - “When to Sign on the Dotted Line: Signing First Makes Ethics Salient and Decreases...more

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