Aristotle said “well begun is half done.” About 2,300 years later, Mary Poppins shared the same advice with her young charges, Jane and Michael. The adage generally is understood to mean that a thoughtful and disciplined...more
The research is clear. A good decision with a bad outcome is likely to be viewed – by others and by the decision-makers themselves – as a bad decision in hindsight. Equally so, a bad decision with a good outcome is likely to...more
Let’s say you’re a publicly traded manufacturer of a popular medical device, which you sell commercially as well as to a number of VA hospitals. You receive an anonymous internal hotline complaint alleging that certain...more
Many lawyers — and most humans for that matter — have a fundamental misunderstanding about persuasion. We are convinced that if we have the better, more logical, more legally sound, more morally righteous argument, we will...more
Welcome back to the 9th edition of OIG Shorts, a publication of the Sheppard Mullin Organization Integrity Group (OIG). This post discusses the importance of a targeted, multi-layered compliance program focused at individual...more
Welcome back to the seventh edition of OIG Shorts, a publication of the Sheppard Mullin Organizational Integrity Group. Today’s discussion focuses on the thorny issue of Ethics & Compliance (E&C) program funding.
Arguing...more
Good morning, and welcome back. This is the sixth edition of OIG Shorts, a publication of Sheppard Mullin’s Organizational Integrity Group. Previously, we discussed several practical approaches to creating a more effective...more
Discipline is a complicated thing. Ask any parent. The fifth installment of OIG Shorts focuses on discipline as a core component of an effective Ethics & Compliance Program.
...more
In our decades working with complex organizations on their Ethics & Compliance (E&C) programs, my colleagues and I have seen a wide variety of structures. While we readily concede there is no one way to structure an E&C...more
Welcome to our third installment of OIG Shorts. Ethics & Compliance programs that buck up against an employee’s reality—whether that reality is real or perceived—have less chance of succeeding. In this third edition of our...more
Welcome back to our second installment of OIG Shorts. In this post, we focus on the difference between Checking Boxes and Solving Problems from an Ethics & Compliance (E&C) perspective. We all know what attributes an E&C...more
U.S. companies spend millions on Ethics and Compliance (E&C) programs every year. While the exact cost varies by industry, company size, etc., there is general consensus that the cost of such programs has increased...more
The inattention some companies pay to their ethics and compliance program never ceases to surprise us. You’d think the frequency of DOJ press releases and prosecutions holding companies accountable for employee wrongdoing...more
Government enforcement efforts are on the rise. In December 2021, the Secret Service announced an initiative to more aggressively counter pandemic-related fraud. Empowered by new personnel, new funding, and new legislation,...more
Originally published in the San Diego Business Journal on January 21-27.
It has been noted, the more things change, the more they stay the same. In the world of Government Contracts Law, however, the more things change,...more