News & Analysis as of

Ethics

The Importance of Compliance Program Audits

by Michael Volkov on

Chief compliance officers spend a significant amount of time comparing their compliance programs with other companies’ programs. CCOs often find solace when benchmarking their respective programs against other companies’...more

Working in a “Happy Talk” Corporate Culture

by Michael Volkov on

Honesty is the best policy – when there is money in it. – Mark Twain - Compliance professionals encounter a diverse range of corporate personalities in their work. To be sure, compliance officers have to rely on their...more

CCO Leadership: Lessons from Kaiser Permanente

by Thomas Fox on

One thing every Chief Compliance Officer (CCO) will face is multiple stakeholders. The more compliance is operationalized the more sensitized this issue will become. Yet the centralized control that many business leaders have...more

Poor Performing CEOs and Boards and Compliance Disasters

by Michael Volkov on

The business headlines are filled with the latest corporate scandal – Uber’s defective culture, CEO misconduct and reprehensible comments by supervising board members. Uber is just one of several significant companies caught...more

Incorporating Employee Storytelling into Your Compliance Marketing

by Thomas Fox on

As you might suppose I read quite a bit. One of the pleasures I receive each month is when the copy of the MIT Sloan Management Review arrives. I also find the articles highly topical and present ways to consider new...more

CCOs and Resources: Put Your Money Where Your Mouth Is!

by Michael Volkov on

The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot...more

Are Risk Assessments Just a Report on the Obvious?

by Michael Volkov on

If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say? Let’s start with the cynical side – not that I am a pessimist. Many CCOs...more

5 Telltale Signs of a Weak Corporate Culture

by Michael Volkov on

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the...more

This Week in FCPA-Episode 57, the Father’s Day Edition

by Thomas Fox on

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

The Ethics Advisor: Cuidado with Decisions that Hit Too Close to Home (Literally)

by Best Best & Krieger LLP on

Mi casa es su casa is a good rule of thumb in a close, tight-knit community, and welcoming friends and neighbors into the fold for celebrations and gatherings is ingrained in many peoples’ DNA. Nevertheless, when it comes to...more

Two Steps Forward, One Step Back – Mixed Bag of Compliance Progress

by Michael Volkov on

Companies are embracing the value of compliance and ethics. Interestingly, companies are implementing robust compliance programs, and enhancing such programs with a focus on ethical business values and decision-making. These...more

The Uber Board Report – Part I

by Thomas Fox on

On Tuesday, the law firm of Covington & Burling LLP (Covington), released its long-awaited report (Report) to the Special Committee of the Board of Directors of Uber Technologies, Inc. (Uber). It is truly one of the most...more

China Compliance, From Someone Who Knows

In today’s compliance environment, though we see a robust debate on what the new US administration might mean for anti-bribery compliance, the new ISO standard, and the recent DOJ “Evaluation of Corporate Compliance Programs”...more

Attorneys’ Professional Duty of Care When Representing Clients in Litigation or an Investigation Requires Higher Technological...

by BakerHostetler on

The legal practice and technology go hand in hand, and a solid understanding of technology is crucial to satisfy the ethical duties owed by attorneys to their clients. In an opinion published on Feb. 21, the New York County...more

Compliance Into the Weeds-Episode 42, the Uber Edition

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive into the corporate governance fiasco which is Uber. We consider the revelations in the failures of corporate governance, culture and internal controls at the organization....more

Investigation Challenges

by Thomas Fox on

Today I conclude my three-part series on internal investigations with Jonathan Marks, a partner at Marcum LLP and a well-known internal investigation expert, by considering some of the challenges you may well face during an...more

PACs, Campaigns and Dark Money: What is the Law?

by Stinson Leonard Street on

In 2016, Missouri voters enshrined new campaign finance laws in the state constitution. The Missouri Ethics Commission issued several interpreting opinions and a federal court has enjoined parts of the law as...more

A CCO’s Challenge: How to Convince a CEO to Embrace Compliance

by Michael Volkov on

A Chief Compliance Officer faces many challenges in designing and implementing an effective ethics and compliance program. If a CCO conducts appropriate due diligence before joining the company, he will know the challenges he...more

Day 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

by Thomas Fox on

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more

The Stoic's Guide to Compliance

by Thomas Fox on

One thing about successful Chief Compliance Officers (CCOs) and other compliance practitioners is they can take in severe news, keep calm and carry on. In a keynote speech to the SCCE Compliance and Ethics Institute, Jenny...more

The Spirit of Compliance

by Thomas Fox on

One of my weekend pleasures is reading Peggy Noonan’s column in the Wall Street Journal (WSJ). Each week is filled with wit and insight and some of the finest writing around. This past week, in an article entitled “Why...more

Whistleblower Hotlines: Still a Vital Tool

by NAVEX Global on

Recently the chief compliance officer of a global company asked me: does a company need a telephone-based whistleblower hotline anymore? In our all-technology, all-the-time world, could a company phase out telephone hotlines...more

Character from the Top: An Interview with Fred Kiel

by NAVEX Global on

Fred Kiel and his team at KRW International spent seven years studying almost 100 CEOs, their executive staff and their employees. The goal? – To devise and implement a quantifiable way to answer the question: Does a leader’s...more

Promoting an Ethical Culture — Actions Not Just Words

by Michael Volkov on

With an increasing focus on the value of an ethical culture, I have been reading more about chief ethics officers, the separation of ethics and compliance, and the traveling ethics officer who meets with employees to discuss...more

Compliance into the Weeds-Episode 40, COSO ERM Framework Update

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...more

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