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Five easy steps to implement a whistleblower hotline

In 5... 4... 3... 2... 1... The ACFEs 2014 Report to the Nations states that the most effective method for reducing workplace fraud is to implement an ethics hotline to allow and encourage employees, customers, and...more

Discipline and Rigor in Your Internal Controls

In a recent New York Times (NYT) Op-Ed by David Brooks, entitled “The Good Order”, he discussed how routine can lead to creativity. He cited to the example of three well-known authors whose habits included the following....more

FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions [Video]

In this episode I visit with Scott Killingsworth, partner at BryanCave on his thoughts around the compliance solutions found in private-to-private compliance obligations. ...more

TNG Premiers and Internal Controls for Gifts in a Best Practices Compliance Program

This week, 27 years ago, Star Trek – The Next Generation (TNG) made its television debut. Rarely has there a follow up to a beloved original series (Star Trek – The Original Series (TOS)) that is equally treasured by fans. ...more

West Side Story and GSK In China – Board Oversight and Tone in the Middle

Yesterday, I celebrated the anniversary of one of America’s cultural lows. But today, I am extremely pleased to open with exactly the opposite, that being one of America’s greatest gifts to the performing arts....more

FCPA Compliance and Ethics Report-Episode 94-Internal Controls for Gifts, Travel and Entertainment in a FCPA Compliance Program,... [Video]

In this episode of the FCPA Compliance and Ethics Report I continue my visit with Henry Mixon on internal controls for gifts, travel and entertainment in a best practices FCPA compliance program. ...more

AB1825 Training In 2015: “Nudging” Employees To Do The Right Thing

What factors go into decision making? Would you argue that how a situation is framed impacts how you react? Of course. Let’s consider the following situation, and apply the same logic to improve our AB1825 Training...more

Getting Schooled by the FPPC - AB 1234 Ethics Training Can Safeguard School Officials from FPPC Reporting Violations

The Fair Political Practices Commission has initiated a proactive approach to auditing and investigating reporting violations, some focused on school district officials. Rather than waiting for a violation to be brought to...more

Users Choose The Rules of Reddit – Which Is Why They Need Code of Ethics Training

If you haven’t heard about it already, or maybe you are just like me and try and stay out of the celebrity gossip as much as possible, there has been a leak of several celebrities’ nude photos across the internet. Celebrities...more

FCPA Compliance and Ethics Report-Episode 92-Interview with Matt Kelly [Video]

The FCPA Compliance and Ethics Report is out. In this episode I visit with Matt Kelly, editor of Compliance Week about the upcoming Compliance Week Europe and Compliance Week West conferences, the COSO framework and internal...more

When Bribery Pays, People Bribe

As Alison Taylor (Senior Managing Director, Control Risks) stated in a recent Forbes Article, “Compliance and Risk: Clearing the Org Chart Hurdle, “the traditional preventative approach to risk management is proving...more

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II [Video]

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

How To Identify The 14 Red Flags Of Ethical Misconduct & Mitigate Them With Your Compliance Training Program: Part 1

This week I had the pleasure to attend SCCE’s 14th Annual Compliance & Ethics Institute in Chicago. The first session I attended was led by Carolyn S. Egbert, Owner and Founder of Creative Solutions for Executives. Her...more

The Research Is In: Busy People Are Less Compliant

Demanding work environments are common today. But new research has identified a previously hidden cost to pressure-filled organizations, says Gretchen Gavett of the Harvard Business Review: “neglecting those secondary tasks...more

Use of Influence in the Compliance Function

One of the challenges for any Chief Compliance Officer (CCO) is how to influence the conduct and actions in a corporate environment, particularly as compliance is viewed as non-revenue generating and usually does not exist...more

Bruce Levenson Takeaways, Plus 5 History Lessons To Add “Oomph” To Your Business Ethics Training

It’s amazing to me that we’ve made it to 2014 and we’re still hearing widespread reports of racism and race-based harassment and discrimination. In 2013, the EEOC received 8,519 race-based harassment and discrimination...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

Four steps to manage your whistleblower complaints

How do you manage your whistleblower complaints? Getting employees to speak up when they see signs of wrongdoing is hard. Many employees struggle with initially "taking the plunge" (because that's how it may feel) for...more

FCPA Compliance and Ethics Report-Episode 88, Internal Controls for Third Parties Under the FCPA, Part I [Video]

In this episode 88 of the FCPA Compliance and Ethics Report, I visit with noted internal controls expert Henry Mixon on the types of internal controls needed for third parties in a FCPA compliance program. ...more

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

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