Ethics

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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

Ethical Challenges of Aggregate Settlement Agreements

Aggregate settlements pose several ethical challenges, primarily because they involve lawyers representing the interests of more than one client. Care must be taken at all times to ensure the interests of all clients are...more

3 Questions To Help Develop Ethics and Compliance KPIs (Beyond Business Ethics Training Scores and Whistleblower Hotline Calls)

It’s no secret that ethics and compliance professionals struggle with measuring the effectiveness of their programs. Sometimes the “well, we have to do it anyway” mentality can preclude any attempt at real measurement and...more

Ethical vs. Illegal

We get up. We go to work. And each day our working environment is subject to similar challenges that we face in society - differing types of people, cultures, personalities, and unethical behaviour. We juggle this everyday....more

Healthcare Ethics and Compliance Program Requirements

The Affordable Care Act included a mandate that medical service providers and suppliers enact compliance programs as a condition of participating in federal health care programs. (The ACA also set a deadline of March 23,...more

How A Failure to Set Tone-at-the-Top Led to a Fractured Vertebra

What does ‘Tone-at-the-Top’ mean to any anti-bribery or anti-corruption program? Conversely, what if management says to do the right thing but only judges employees on their sales; what is the message that only ‘Talking The...more

FCPA Compliance and Ethics Report-Episode 73-World Cup Report-Part V [Video]

In this episode, Mike Brown and I look at the assessment of 'Tone at the Top' from the perspective of the Brazil/Colombia World Cup final and the horrific injury to the Brazilian striker Neymar. ...more

Unethical Companies Capitalizing on Employee Deaths: Protect Your Reputation with Compliance Training

It came as sort of a shock to me the other day when I came across the article in Fortune titled, “The many ways companies profit from hastening employees’ deaths.” What I took away from it was that companies are taking out...more

CCO Challenges in the Healthcare Industry

Chief Compliance Officers have a tough job. It does not matter what industry they are working in, CCOs face a myriad of challenges. The healthcare industry, however, has its own set of challenges. While there has been...more

Does Your Compliance Training Inspire Employees to Follow Rules or Follow Values?

I read an article in the Wall Street Journal wherein Michael McMillan, director of ethics and professional standards at the CFA Institute, was interviewed and discussed the difference between following the rules and behaving...more

Text F for Fraud

Most of us already pay a fortune on our monthly cellphone bills, but if you were a T-Mobile customer between 2009 and December 2013, you may have been cheated into paying additional charges as well....more

Bar Associations: Protecting Consumers or the Status Quo?

Some Bar Associations are behind the times. And some are challenged by the dual and potentially conflicting roles they play: one, to self-regulate the practice of law in order to protect consumers; and two, to protect the...more

Compliance in the C-Suite

The ongoing debate whether certain executives are “too big to jail” misses the most important trend in corporate governance – namely, that criminal conduct is rising in the C-Suite. Viewed from a broad perspective, since...more

FCPA Compliance and Ethics Report-Episode 72-interview with Michael Rasmussen [Video]

In this episode of the FCPA Compliance and Ethics Report, I interview Michael Rasmussen, the GRC Pundit. As the man who coined the phrase 'GRC' Michael is one of the country's top GRC experts. He talks about the recent OCEG...more

More Fallout From American Apparel: CEO Refused Mandatory Sexual Harassment Training

Let it never be said that ethics and compliance is a dull field. Some of the stories that happen in it are worthy of Hollywood. In my last post about American Apparel firing CEO Dov Charney, I wrote that this happened after...more

Hot Compliance Training Trends and Best Practices for Engaging Millennials: Gamification, Animation, and More!

It’s not like you don’t have enough to do – it’s like you’ve suddenly become the Chief of Education in addition to the Chief Compliance Officer. You’re expected to be up to date on all the latest trends in adult education....more

Three Ethics & Compliance Program Insights You Can’t Afford to Miss

In the first half of this year, I interviewed and conducted focus groups with hundreds of line employees, professionals and managers on four continents and—regardless of country, culture or industry—three themes came up again...more

CCOs Need To Adopt Their Own Code of Conduct

As CCOs become a key player in the corporate governance world, ethics and compliance leaders are developing principles to be used by compliance pofessionals. It is a natural process that reflects the growing...more

Increasing Risks of Fraud; Compliance Failures; A Willingness to be Unethical

Cyber security, corruption and unethical behavior pose significant risks for business enterprises, according to a new survey by EY titled “Overcoming Compliance Fatigue’. At the same time business organizations may be...more

Four Reasons Why Employee Social Media Training Is Essential (Hint: It’s Not Just About Compliance!)

And before I forget, let’s make that effective social media training, shall we? Pam Moore wrote this great article “Social Media Policy & Governance: 17 Tips to Mitigate Social Business Risk.” It’s quite insightful and...more

LCIA Draft Rules 2014: addressing emergencies, efficiencies and ethics

It seems that it could be all change at the London Court of International Arbitration (LCIA), with new arbitration rules anticipated to come into force later this summer. The draft rules, which the LCIA published earlier this...more

The Final 6 Psychological Phenomena Undermining Your Compliance Training

Perhaps due to one of the aforementioned psychological reasons good people do bad things, someone has already behaved in an unethical manner. The induction mechanism postulates that the more people behave badly, the less they...more

FCPA Compliance and Ethics Report-Episode 70-World Cup Report-Part III [Video]

In this episode, the World Cup Report Part II. Mike Brown and I continue our exploration of compliance lessons from FIFA and the 2014 World Cup. We discuss why following the money is so critical, then analyze the US tie with...more

South Carolina Legislative Update

The House and Senate met last week to consider gubernatorial vetoes and conference reports. The House adjourned last Tuesday and is expected to return this summer to take up the veto of S. 813 (Public Library Trespass), which...more

FCPA Compliance and Ethics Report-Episode 69-Joe Oringel, co-founder of Visual RiskIQ on Transaction Monintoring [Video]

In this episode, I visit with Joe Oringel, co-founder of Visual RiskIQ. Joe talks about transaction monitoring and the tool that his company has developed to assist companies with FCPA compliance. ...more

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