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Ethics

Talking About Bribery in the Country Where I Bribed

I recently returned from a week in Amsterdam, addressing front-line compliance challenges, and attending several anti-corruption conferences. It was a surreal experience for me, for in 2003 I paid a “Dutch Agent approximately...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Klaus Kleinfeld is out as CEO of Alcoa-subsidiary Arconic. Kleinfeld’s two-year tenure was marked by problems, and Kleinfeld did himself no favor with an un-Board-authorized letter that he sent to activist-investor Elliott...more

20 Questions to Ask when Prioritizing Your Policy Development Efforts

by NAVEX Global on

Having too many policies can burden your organization, but having too few exposes it to unnecessary risk. That means we need to prioritize which policies we will develop (or revise) first. As a rule of thumb, policies are...more

Sunshine Superman – When Culture is Not My Problem

by Thomas Fox on

Today we honor folk-rocker Donovan and his signature song Sunshine Superman, which was profiled in the Wall Street Journal (WSJ) column Anatomy of a Song. The song was a love paean by the singer to “Linda Lawrence, his love...more

Wells Fargo’s Desperate Need for a Compliance and Business Ethics Function (Part III of III)

by Michael Volkov on

While reading the independent directors’ report on the Wells Fargo sales incentives scandal, you will be overwhelmed by the feeling of frustration. At the same time, what is described in the report is the extent to which...more

Code of Conduct Week: Part V – Operationalization

by Thomas Fox on

I have reviewed the creation and update of a Code of Conduct this week, with a big assist from Eric Morehead, the Principal of Morehead Compliance Consulting. We reviewed the legal requirements, the suggested structure and...more

Code of Conduct Week: Part IV – Training on Your Code of Conduct

by Thomas Fox on

Today focus in the Code of Conduct series is on the aspect of training on your finalized Code of Conduct. Eric Morehead, Principal of Morehead Compliance Consulting, joins me in this series. While there have been criticisms...more

Code of Conduct Week: Part III – Design of Your Code of Conduct

by Thomas Fox on

Today I continue my Code of Conduct exploration with Eric Morehead, Principal of Morehead Compliance Consulting. After having reviewed the legal requirement and business purpose in Part I, the structure and form of your Code...more

Code of Conduct Week: Part I – Introduction

by Thomas Fox on

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

How to garner a NPA and Declination

by Thomas Fox on

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program as there where two public declinations granted by the DOJ for companies...more

Lessons on Culture and Trust from Military Strategy

by NAVEX Global on

Last month we introduced an occasional series of posts about organizational trust: what it is, how it helps a business succeed, why trust is declining these days, and how companies can nurture a rigorous ethical culture based...more

The Three Lines of Compliance Offense Versus The Three Lines of Compliance Defense

by Michael Volkov on

People crave simple solutions to complex problems. No, this is not a political statement, nor do I intend to wade into politics. This statement applies across the board – to business, compliance, government, and other...more

Ninth Circuit Court of Appeals Adopts Broad View of Whistleblower Protection Under Dodd Frank

by NAVEX Global on

On March 8, 2017, the United States Court of Appeals for the Ninth Circuit held that the Dodd Frank anti-retaliation provisions protect individuals who complain internally and are not strictly limited to those individuals who...more

New Ethics and Campaign Contribution Rules Enacted in San Francisco

by Perkins Coie on

San Francisco voters enacted Proposition T by an overwhelming majority in the November 2016 election; the measure was placed on the ballot by a unanimous vote of the San Francisco Ethics Commission. The measure will make an...more

The Five Levels of Building an Ethical Culture

How to build and sustain an organization whose employees are happy, motivated, and ethical remains one of the most complex, elusive questions confronting business leaders. Organizational culture is determined by the...more

Is a “Very Strange Year at Uber” a Cue to Improve Culture or Harassment Training …or Both?

by NAVEX Global on

Whenever we see headlines about an organization embroiled in some kind of ethical or legal misstep, what usually follows are a series of questions about what exactly went wrong. The answers to these questions usually shine a...more

FCPA Compliance Report-Episode 318-Erica Byrne on Ethisphere's 2017 World's Most Ethical Companies [Video]

by Thomas Fox on

In this episode, I visit with Erica Salmon Byrne, EVP at Ethisphere on the 2017 World’s Most Ethical Companies honorees. Erica goes into how the corporate compliance programs are evaluated, what the companies disclose to...more

Leadership Lessons from the Movies

by Thomas Fox on

Today, I wanted to consider some of the recent leadership lessons I have explored on my podcast, 12 O’Clock High, a podcast on business leadership. In the series, host Richard Lummis and myself, mined some of our favorite...more

Building Trust in an Organization as a Step to Operationalizing Compliance

by Thomas Fox on

Earlier this week I explored LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report). One of the key findings of the Report was that if there was greater employee trust, the values of ethics...more

Whacky Employment Claims: Who's Whackier? Management or the Employee?

by Lewitt Hackman on

As employment defense attorneys, we see many strange situations arise in the workplace. The question is, how prepared are you as an employer to handle the wackiness that may potentially arise when your employees make...more

2017 EMEA & APAC Culture and Compliance Benchmark Report - Data And Insights To Put To Work In Your Programme Today

by NAVEX Global on

NAVEX Global partnered with an independent research agency to investigate how companies headquartered across Europe, Middle East and Africa (EMEA) and Asia Pacific (APAC) develop and execute their ethics and compliance (E&C)...more

Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV)

by Michael Volkov on

Here is a profound grasp of the obvious – Lawyers can be difficult people. Some like to condemn the profession in its entirety (and carry with them a collection of lawyer jokes). As an attorney, I beg to differ. Many...more

Startup Culture Seems to Be Missing One Key Ingredient—Culture

by NAVEX Global on

Sometimes when I read tales of startups riddled with problems of corporate culture and poor conduct, I want to grab the founders by their shoulders and shout, “You’re doing it wrong!” I suspect I’m not alone among compliance...more

LRN Compliance Program Effectiveness Report: Part III

by Thomas Fox on

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

Getting to Know You, Getting to Know All About You — Business Buy-In to Compliance Functions (Part III of IV)

by Michael Volkov on

We all know that a compliance program without business buy-in is, by definition, an ineffective compliance program. The level of business support ranges from “mouthing” support to full-fledged embrace and ownership of...more

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