News & Analysis as of

Use of HR in Your FCPA Compliance Program [Video]

In this episode of the FCPA Compliance and Ethics Report, I discuss how HR can help to facilitate your compliance program. ...more

What Are Internal Controls, Part I [Video]

In this episode of the FCPA Compliance and Ethics Report, I begin a series on internal controls, with noted practitioner Henry Mixon. This is the first part of a two part episode on the basics of what are internal controls. ...more

Unexpected “Scientific Evidence” on the Value of Ethics & Compliance Training and Communications

A real-life situation recently provided powerful evidence of the value—and effectiveness — of ethics and compliance training and communication. When scientists want to prove the effect of something such as, for...more

How due diligence plays a role in anti-corruption compliance

With the increasing frequency and expanding scope of enforcement globally, organizations need to devote plenty of attention to anti-corruption due-diligence of third-parties that they engage. The value of due diligence is...more

Justin Bieber Does It Again – Time For Anti Bribery Training To Save The Day

Tsk tsk tsk. Just when I thought I was only going to mention him in one blog post this year, I now have the opportunity to write another. Someone has to do it! Justin Bieber is back in the spotlight and this time it isn’t...more

Corruption, Risk and Business Strategy. Which one manages the others?

Since I stared writing about issues relating to compliance at the front line of international business, I have found myself looking more and more at the role of business strategy as a significant foundation of anti-bribery...more

How not to ignore ethics, in one simple lesson

Need a ride home? Obviously there's an app for that! Get out your smart phone, find your bookmarked app, and instantly get connected with a driver who will come pick you up from your current location, and drop you off...more

FCPA Compliance and Ethics Report-Episode 82, continued fallout from GSK in China [Video]

In this episode of the FCPA Compliance and Ethics Report, I review the continued fallout from GSK in China. I discuss the trial of Mr and Mrs Humphreys and what it all means for the compliance practitioner going forward. ...more

Creating a Culture of Ethics and Compliance [Video]

An effective compliance program requires a culture of ethics and compliance, including "tone-at-the-top." A company's culture is not easy to measure. Nonetheless, there are practical steps which can be implemented to collect...more

Happy Birthday Dodd-Frank: The Whistleblower Program Milestones and How They’ve Impacted Business Ethics Training

Did you have some cake? Break out the balloons? While it’s hard to believe, it is true. Our little Dodd-Frank, signed into law by President Obama in 2010, is already four years old and about ready for pre-school. Although we...more

The Absence of a CECO and the GM Fiasco

This is a posting that I have wanted to write since the GM scandal occurred. I have to start with a rhetorical question – Would the GM debacle have occurred if GM had an independent and empowered Chief Ethics and Compliance...more

Addressing & Alleviating Top Compliance Training Challenges & Barriers

More than half (56 percent) of the respondents to the NAVEX Global 2014 Ethics & Compliance Training Benchmark Survey revealed that their top ethics and compliance training concern today is the limited hours available for...more

Uber Plays Dirty – Why The Company Needs An App For Business Ethics Training

We have all experienced that moment where, while we don’t plan on drinking that much, one jack and coke leads to another…and another…and…another, and then he bar is suddenly transformed into an intense merry go round… and,...more

Sunshine Ordinance Preempted by City Charter Provision Creating Attorney-Client Privilege

The First District Court of Appeal determined that City of San Francisco (“City”) resident Allen Grossman (“Grossman”) was not entitled to documents related to the development of certain San Francisco Ethics Commission...more

Legal Ethics Resources

Substantial information on legal ethics is available on the Internet, including: http://www.law.georgetown.edu/library/research/guides/legal_ethics.cfm, a broad-based Legal Ethics Research Guide offered by Georgetown...more

Thinking Through Risk Rankings of Third Parties

One question often posed to me is how to think through some of the relationships a company has with its various third parties in order to reasonably risk rank them. Initially I would break this down into sales and supply...more

How Vendors Can Add Value to Your Resource-Constrained Ethics And Compliance Training Program

Too many times we see the providers of ethics and compliance services disappear after they have sold an ethics and compliance training program or ethics and compliance policy management system. ...more

Five Keys to Reducing Behavior Risk During Mergers, Acquisitions and Other Major Organizational Change

A recent blog post by Ethics Resource Center President Pat Harned, reported on findings from the ERC 2013 National Business Ethics Survey (NBES) of significantly more observed misconduct in companies that are under stress...more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Termination of a Third Party or Breaking Up Should Not Be Hard To Do

One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine. Not only does...more

The Majors, The Minors and Antitrust Training

In my last antitrust training blog, I admitted I didn’t know much about it and that I frankly thought of the topic as much less popular than others in most ethics and compliance training libraries. After writing about it,...more

The Houston Astros and a Compliance Defense in the FCPA

The Astros act like a corporation and like almost all corporations they look to pay the absolute cheapest that they can to get something. Those who advocate that there be a compliance defense added to the FCPA miss this...more

How to Form Teaming Agreements and Strategic Partnerships

In this presentation: - Teaming - Subcontracting - Joint Ventures - Q&A - Excerpt from Teaming: Once partners are selected, prepare and sign a Teaming Agreement: - What...more

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

This one is tough, especially in global organizations. In many countries, you simply cannot run a background check, as criminal records are not public. In others, you can run them, but the criminal offense must be related to...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

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