In my July column, I wrote about the connection between corruption and the environment. But corruption also has a link to the “S” of the environmental, social, and governance (ESG) pillars. Corruption is both a cause and a...more
9/4/2024
/ Compliance ,
Cooperative Compliance Regime ,
Corporate Governance ,
Corruption ,
Ethics ,
Financial Crimes ,
Forced Labor ,
Fraud ,
Governance Standards ,
Human Trafficking ,
Popular ,
Slavery ,
Supply Chain
Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more
7/31/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Civil Monetary Penalty ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Employees ,
Ethics ,
Internal Investigations ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
United Arab Emirates (UAE)
Writing, implementing, and enforcing strong compliance-related policies is critical to any compliance and ethics program. So, why do so many compliance failures occur due to breakdowns in internal controls?...more
7/15/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Communications ,
Corporate Culture ,
Corporate Governance ,
Employees ,
Ethics ,
Internal Controls ,
Policies and Procedures ,
Strategic Enforcement Plan ,
Training
2024 represents the 25th anniversary of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials, which has now been signed by 46 countries—including eight...more
6/4/2024
/ Anti-Bribery ,
Anti-Corruption ,
Best Practices ,
Bribery ,
Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Governance ,
Corruption ,
Ethics ,
Noncompliance ,
OECD ,
Regulatory Requirements ,
Risk Management
A recent issue of SCCE’s Corporate Compliance Weekly News contained a link to a startling report I was not previously familiar with. An investigation by the U.S. Coast Guard found numerous instances of sexual assault spanning...more
4/26/2024
/ Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Disclosure ,
Ethics ,
Internal Controls ,
Internal Investigations ,
Risk Management ,
Self-Reporting
As we’ve noted here before, numerous environmental, social, and governance aspects have very clear compliance ramifications, whether in the form of laws and regulations or stakeholder expectations that can result in serious...more
4/26/2024
/ Chief Ethics and Compliance Officers (CECO) ,
Climate Change ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corporate Social Responsibility ,
Environmental Social & Governance (ESG) ,
Ethics ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
I recently read about a banker being fired for inflating his expense report to the tune of a sandwich, some pasta, and a coffee. A judge ruled in the bank’s favor in a wrongful dismissal suit filed by the former...more
Inspiration for this month’s column came from a recent article written by Amber MacArthur, who spoke at SCCE’s Compliance & Ethics Institute several years ago. I’ve followed Amber for years, often finding her writing to be...more
Perhaps you haven’t pondered this question. On work-from-home days, do burglars break into their own homes? Or is this time spent doing research, preparing plans, taking online training courses on emerging best practices,...more
10/3/2023
/ Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Ethics ,
Healthcare ,
Healthcare Reform ,
Professional Development ,
Professional Networking ,
Relationship Development ,
Remote Working ,
Research and Development ,
Training
In May, I had the opportunity to participate in a panel discussion on the harmonization of American and European approaches to compliance and ethics at the 7th Compliance & Technology Conference of the Institut du Risk &...more
I’ve written about proving intent before, but a recent session (and subsequent conversation) at a conference reminded me of its importance, as well as a common misconception. Not all laws require intent be proven; some are...more
I can’t think of a better example of the convergence of environmental, social, and governance (ESG) factors, compliance, and ethics than in marketing and public relations. This area is filled with opportunities and risks...more
7/13/2023
/ Business Strategies ,
Compliance ,
Corporate Governance ,
Corporate Social Responsibility ,
Diversity and Inclusion Standards (D&I) ,
Environmental Social & Governance (ESG) ,
Ethics ,
Federal Trade Commission (FTC) ,
Greenwashing ,
Marketing ,
Public Communications ,
Public Relations ,
Reporting Requirements ,
Risk Management ,
Shareholders
As I write this in early April, we are fresh off an invigorating 11th-Annual European Compliance & Ethics Institute (ECEI) held in Amsterdam. ECEI was an in-person-only gathering of more than 300 people representing 30...more
A recent news report reminded me of how difficult it can be to manage compliance and environmental, social, and governance (ESG) risks. You may have seen the report: a tiny capsule the size of a small coin fell out of a truck...more
I appreciate that you are reading this magazine and its useful information regarding compliance and ethics. But I’d like to use this month’s column to encourage you to read something else—a good book that has nothing to do...more
This month’s column is devoted to the idea of “testing out” of compliance training, a topic I addressed in my opening comments at the Compliance & Ethics Institute in October, but in a clumsy manner. I think I came across as...more
I managed not to lose my temper when a training skeptic informed me that he wasn’t a fan of compliance training because “it’s not going to make a dishonest person do the right thing.” Indeed, I doubt anyone who previously had...more
2/2/2023
/ Best Practices ,
Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Employee Training ,
Employees ,
Ethics ,
Policies and Procedures ,
Risk Assessment ,
Risk Management ,
Training
For inspiration in writing this month’s column, I looked no further than my own colleague, Adam Turteltaub, SCCE & HCCA’s chief engagement and strategy officer, who wrote a piece for the Society of Corporate Compliance and...more
CEP Magazine - November 2022 -
Much has been made lately about whether environmental, social, and governance (ESG) as we know it is already failing and about to go away, only to re-emerge with a new twist and a new label....more
CEP Magazine - November 2022 -
Inspiration sometimes comes from unexpected places. I like to read books on a variety of topics. In one I read recently, the astrophysicist author described the second law of thermodynamics...more
CEP Magazine (June 2022) -
One of the best methods of learning about compliance and ethics programs is to review enforcement actions. And some recent actions provide very useful guidance regarding one of the most...more
Environmental, social, and governance (ESG) issues have been around for many years under a variety of different names (e.g., sustainability, etc.). Until recently, ESG was often considered to be a public relations function,...more
There has been much discussion over the years about the relationship between enterprise risk management (ERM) and compliance risk management. Making the discussions more complex has been a tendency to approach risk management...more