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Corporate Branding and Ethics and Compliance Charters and Policies

There is a lot written on the value of symbols in political and public relations campaigns. My favorite President, Franklin Roosevelt, was a master at using symbols to communicate powerful ideas to the public....more

Compliance Program Effectiveness Requires Accountability

A compliance program requires accountability. You can have ethics and you can have compliance policies, procedures and all the bells and whistles, but someone has to be accountable....more

Trust in the Balance

This tough Cookie is grateful to have been asked to submit some articles for Tom Fox while he visits with his daughter during Spring Break. When I pondered what would be an appropriate topic for the week, immediately...more

The Importance of Organizational Justice

A company is its own world. A culture of ethics and compliance cannot exist without organizational justice. If company managers and employees perceive that the internal justice system does not work, the company will be...more

Ingots of Gold & SEC FCPA Enforcement – Communication – Part IV

Today I want to use the Christie’s story Ingots of Gold as an introduction to some of the regular communications that the Securities and Exchange Commission (SEC) representatives frequently provide in public forums, regarding...more

Ethics and Compliance, Not Compliance and Ethics

I have several pet peeves in the ethics and compliance space (who knows, maybe in the personal space as well but we are all reluctant to acknowledge those except to our loved ones)....more

Does Compliance Need More “Darkside”?

Since my release from the Federal Prison Camp in December 2013, I have been observing many different perspectives in the compliance discourse that have broadened my own understanding of “compliance”. From the fields of law,...more

Commerzbank’s Compliance Catastrophe — Flouting Sanctions and BSA/AML Laws (Part II of III)

Sometimes a picture is very clear but legal words and concepts are proffered in an attempt to disguise and even deceive. As set forth in the factual statements outlined by the government, and agreed to by Commerzbank, it is...more

Webinar - Benchmarking Your Hotline in 2015: How Does Your Data Measure Up?

Ethics officers agree—one of the most effective ways to measure your compliance program is by analyzing data from internal reporting systems. But how can you know what is good or bad without context? We’ve compiled...more

Protections for CCOs from Wrongful Termination

This week the Houston Texans unceremoniously cut the franchise’s greatest player in its short history, receiver Andre Johnson. This was after his being hauled into the office of the head coach and being told that he would...more

NAVEX Global’s 2015 Ethics and Compliance Hotline Benchmark Report: Three Ways to Put Our Data to Work for You

Ethics and compliance professionals regularly gather and analyze report data made through their numerous reporting systems. What they do with this data may mean the difference between identifying potential problems early, or...more

FCPA Compliance and Ethics Report-Episode 139-Amy Lilly, President of GHBER [Video]

In this episode I interview Amy Lilly, President of the Greater Houston Business and Ethics Roundtable (GHBER), the premier ethics and compliance organization in Houston. ...more

Reminders from the Goodyear FCPA Settlement

FCPA settlements carry with them a basket of compliance and enforcement lessons. The recent Goodyear settlement with the SEC for $16 million carries some important compliance and strategic reminders for ethics and compliance...more

FCPA Compliance and Ethics Report-Episode 138, Tribute to Mr. Spock and Strict Liability for Internal Controls Under the FCPA [Video]

In this episode, I pay tribute to Leonard Nimoy and his immortal character Mr. Spock. I also discuss that the SEC may be moving towards a strict liability standard for internal controls under the FCPA....more

Financial Institutions and Ethics – Some Just Do Not Get It

I am starting to repeat myself – it is a sign of old age (ask my wife), or maybe I have a point to make. I have written several times about financial institutions and the need to embrace a culture of ethics and compliance....more

Corporate Board Responsibility for Compliance

You can talk all you want about the importance of “tone-at-the-top.” People use that term all the time and everyone nods their heads in agreement. But what is the “top”? Is it the CEO? Is it senior executives? Is it the...more

Tenth Quarterly Report Of The Independent Athletics Integrity Monitor Pursuant To The Athletics Integrity Agreement Among The...

This is the tenth quarterly report of the independent athletics integrity monitor (“Monitor”) pursuant to article IV of the Athletics Integrity Agreement (“AIA”) among the National Collegiate Athletic Association (“NCAA”),...more

FCPA Compliance and Ethics Report-Episode 136, Joel Borgquist, President of Etik [Video]

In this episode, I visit with Joel Borgquist, President of Etik a company that works to insure transparency in corporate social responsibility programs and assists in conflict resolution. ...more

FCPA Compliance and Ethics Report-Episode 135, Kevin Brady on the process of sales for the compliance practitioner [Video]

In this episode I visit with noted sales process expert Kevin Brady who discussed sales as a process and how the compliance practitioner can use these concepts in communicating the message of compliance to an employee base. ...more

The Time is Now for Every Company to Conduct Culture Audits

Companies and CCOs are starting to get the message – the best and most effective control against code and legal violations is a culture of ethics and compliance. Those are high-minded ideals for high-level executives....more

Avoiding Silos: Bringing Together the Key Compliance Players

One of my favorite SNL skits from years ago was John Belushi as Henry Kissing, singing “Getting to Know You” with his arms around Menachem Begin and Yasser Arafat – a true classic. The same can be said for the compliance...more

An “Effective” Compliance Program is Not a Perfect One

The golden ring for every chief compliance officer is an “effective” ethics and compliance program. But if you ask a CCO if the company’s compliance program is ”effective,” they will bow their heads and reluctantly admit,...more

Building a Culture-Changing E&C Program: Six Essentials

Compliance programs are effective only to the degree that they help build and support a strong organizational culture. So what does a strong corporate culture look like? And what ethics and compliance tools can help support...more

Future of Corporate Monitors

No company wants a corporate monitor. If you ask any General Counsel, Chief Compliance Officer or Chief Executive Officer, they can list an infinite number of alternative punishments they would rather suffer than have a...more

14 Ways To Make Your Employees Fall In Love With Your Code Of Conduct: Part One

We recently kicked off the year by hosting two ethics and compliance events in Charlotte and Nashville. Lori Tansey Martens, President and Founder of the International Business Ethics Institute, spoke to an exclusive group of...more

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