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What Scuba Diving Can Teach You About Policy Management: Three Key Lessons

What do policy management and scuba diving have in common? The need to mitigate risk, use the right equipment and prioritize training. You might not imagine that scuba diving and policy management could have much in...more

Board Reporting: Elevating Your E&C Program & Engaging the Board

In This Presentation: - The Board’s Roles and Compliance Responsibilities - The Board Report & Briefing vs. Training - Important Considerations for your Board Report - Case Study - How Can I Tell if my Board is...more

Practical Advice on Risk and Compliance Program Assessments

Sometimes the compliance industry makes things harder than they really need to be. As a result, Chief Compliance Officers are left to modify and transform practices and tools to fit the real world. I understand why CCOs do...more

Bribery, Beneficiaries and Guilty Feelings (or lack thereof)

Given the response to my recent Q and A with Jamie-Lee Campbell on “Culture Corrupts,” which from an analytics and engagement perspective, was one of my most read pieces on a global basis since I started blogging, I decided...more

Farewell to Mr. Spock and Risk Assessment Under COSO

Leonard Nimoy died last Friday. He will be forever associated with the role of Mr. Spock in the original Star Trek television show which premiered in 1966. The original series ran for only three years but had a full life in...more

Goodyear’s Settlement with the SEC Emphasizes the Importance of FCPA Due Diligence in M&A Transactions and of Having a Robust...

On February 24, 2015, Goodyear Tire & Rubber Co. agreed to pay more than $16 million to settle charges that two of its subsidiaries allegedly paid $3.2 million in bribes that generated $14,122,535 in illicit profits. The SEC...more

FCPA Compliance and Ethics Report-Episode 130, The Oscars and Compliance, Part IV with Jay Rosen [Video]

In this Part IV of my continued exploration of the Oscars and compliance with Jay Rosen, we look at the touchpoint which Hollywood and the movie industry has which might subject it to FCPA liability. ...more

COSO and Internal Controls – Part V

This post concludes my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

Selfie-Sticks and Risk Assessments

Greetings from Venice and a big thanks to Joe Oringel at Visual Risk IQ for allowing my to post his five tips on working with data analytics while I was on holiday in this most beautiful, haunting and romantic of cities....more

Improving the Message of Ethics and Compliance

To succeed in life, you need two things: ignorance and confidence – Mark Twain - I have a problem with writers, columnists, consultants, bloggers and anyone else who puts a pen to paper (as we used to say) on ethics...more

2015 Trends: #10 Cybersecurity: A Risk that Needs to be on Your Ethics and Compliance To-Do List

The starting point for every ethics and compliance program must always be an analysis of the ethics and compliance risks faced by the organization. In that light, it’s important to listen to James Comey, Director, U.S....more

2015 Trends: #8 Top Whistleblowing Priorities for Compliance Professionals

Last November, the U.S. Securities and Exchange Commission issued its Annual Report to Congress on the Dodd-Frank Whistleblower Program. It is clear that the program is going strong. Following are five key ways compliance...more

Both Sides Now and Asking the Right Compliance Questions

One of my favorite singers has always been Judy Collins. Like most of us, I was introduced to her through her interpretation of Joni Mitchell’s song Both Sides Now which she released in 1967. Joni Mitchell did not record her...more

Reconciling Sales Strategy With FCPA Compliance

When Ethical Boardroom asked me to contribute an article on the Foreign Corrupt Practices Act (FCPA) and international sales strategies, I thought it might be interesting to include an organisational change dimension in...more

OECD Foreign Bribery Report: Leveraging The How, Where And Why Of Bribery To Bolster Your Ethics And Compliance Training Program

In my last blog post, “The OECD Foreign Bribery Report: 7 Insights To Improve Your Ethics And Compliance Training Program,” I identified the seven bribery trends covered in OECD’s Foreign Bribery Report. The report listed...more

The Compliance Advantage in Mexico

A View from the Front-Lines of Compliance in Mexico - Today, I am pleased to welcome Patrick Henz as a guest contributor. Patrick started his career in Compliance at the end of 2007, when he was responsible for the...more

Choosing the Right Vendor Risk Management Software Solution

Traditionally, performing third party due diligence has been primarily a data gathering activity. Now, with access to abundant information sources, the activity—and the challenges—have evolved. How do you manage and...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

NAVEX Global’s Most Popular Ethics & Compliance Matters Articles from 2014

This year, we relaunched our blog with the goal of better serving the ethics and compliance community, providing deeper insights on topics that matter most to E&C professionals, as well as best practices and practical steps...more

Seven Key Actions to Accelerate Your Ethics and Compliance Program

We always hear (and talk about) the rise in the compliance profession. Yes, there is increased demand for CCOs and compliance officers. More lawyers are transitioning into the compliance profession....more

Seamus Heaney and Compliance With a Seat at the Table

I have long been fascinated with the Irish poet Seamus Heaney. I came to know him thought his 1999 translation of Beowulf. While I was aware that he had been awarded the 1995 Nobel Prize for Literature, I did not know his...more

Kickbacks and Bribery

Companies can become hyper-focused on anti-bribery compliance. It is easy to do – just look on the Internet, Twitter and Linked In. There are plenty of groups, hash tags, postings and discussions on anti-corruption issues....more

FCPA Compliance and Ethics Report-Episode 111-Virna Di Palma on the TRACE Matrix [Video]

In this episode, I visit with Virna Di Palma on the newly released TRACE Matrix. This is an extremely useful tool to help companies evaluate a wide variety of corruption and bribery risks on a country by country basis. ...more

C-Suite Risks and Compliance

A nickel ain’t worth a dime anymore. – Yogi Berra With all the hubbub about ethics and compliance, senior managers somehow are able to escape any focus or responsibility for compliance programs except in a managerial...more

Doing Business in India – Corruption Risks and Responses

Recently the US law firm of Foley and Lardner LLP and MZM Legal, Advocates & Legal Consultants in India jointly released a white paper, entitled “Anti-Bribery and Foreign Corrupt Practices Act Compliance Guide for U.S....more

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