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Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part III

So, now you’re ready to start your culture audit… Some key questions you want to ask before you start are: Do I have the support of Executive leadership? If not, go back to your E&C steering committee and work through...more

Are We Giving Up on Ethics & Compliance Programs?

The recently released 13th Global Fraud Survey from EY notes that, despite an aggressive enforcement environment focused on fraud, bribery and corruption, “the percentage of companies that have anti-bribery/anti-corruption...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part I

We’ve talked a lot in our Tales from the Crypt about the signs to watch for that indicate something’s gone wrong, from minor cultural twists to lapses of integrity that are tantamount to criminal activity. We all wish we had...more

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

Designing Cost Effective Risk Assessment Programs May 21, 2014 [Video]

The foundation of every anti-corruption ethics and compliance program is a risk assessment. It is important to design and implement a process to conduct an initial risk assessment, to update the risk assessment, and to ensure...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

Code of Conduct, Compliance Policies and Procedures-Part II

This week, I am reviewing the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and...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

Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

In this issue: - Recent Trends and Patterns in FCPA Enforcement - Recent Trends and Patterns in FCPA Enforcement Enforcement - Actions and Strategies - Statistics - Types of Settlements...more

NAVEX Global 2014 Training Benchmarking Report Webinar: Top Takeaways & Questions

We recently hosted a webinar, “Priorities, Practices and Trends in Training” to discuss the findings from our NAVEX Global 2014 Ethics and Compliance Training Benchmark Report. Some of the key findings from the report,...more

The C-Suite Crucible and International Business: “Motivated Blindness"

In the June 2013 issue of Business Compliance (Baltzer Science Publisher, Anthony Smith-Meyer, Editor), Scott Killingsworth (Partner, Bryan Cave LLP) writes about “Ethics in the Executive Suite: The Best, The Brightest and a...more

Three Security Awareness Training Findings That Will Surprise You

As providers of ethics and compliance training solutions, we never tire of discussing topics like anti-bribery training, sexual harassment training, code of ethics training… and so many more. Lately, we have seen a real...more

UK Companies See The Value of The Code of Conduct As A Promotional Tool – Do You?

I came across this excellent article by The Red Flag Group called “Compliance Pulse: Codes of Conduct in the UK – A study of 100 codes of the largest companies listed on the London Stock Exchange.” The article outlines a...more

World Cup Finale – Compliance Lessons to be learned from Success and Failure

Over the past few weeks, I have written several articles on the lessons a compliance practitioner can draw from this year’s World Cup and the international group which runs the event, the Fédération Internationale de Football...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

FCPA Compliance and Ethics Report-Episode 75-Roy Snell CEO of SCCE [Video]

In this episode I visit with Roy Snell, CEO of SCCE on the upcoming Nation Conference to be held in Chicago in September. ...more

Putting the Ethics Back into Healthcare Compliance

We all know someone who is a pest, a professional colleague, a friend or even a family member. I use the term affectionately and especially when I write postings that are restatements of obvious points....more

Mergers and Acquisitions Under the FCPA, Part I

Today, I begin a three-part series on mergers and acquisitions under the Foreign Corrupt Practices Act. Today I will review the pre-acquisition phase, focusing the information and issues you should review, tomorrow in Part...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

CCOs Take Note: It’s the Culture Stupid

If CCOs are really ready to take the reins and assume a real role in the C-Suite, they need to develop more mature measurements and reports for senior management and the board of directors. We have all seen the color-coded...more

Mid-Year FCPA Report, Part II

Today, I continue my look at what I think were some of the most significant highlights from the first half of 2014 relating to the Foreign Corrupt Practices Act (FCPA). Yesterday, the focus was on corporate and individual...more

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