Improving Your Code of Conduct
Episode 347 -- LRN's Code of Conduct Survey
Conducting Healthcare Compliance Investigations
Third Party Ethical Audits
Tying Corporate Compliance & Ethics Week to Your Values
Patty Houser on Supplier Codes of Conduct
Abdul Rahman Al Jaabari on a Virtual Reality Code of Ethics & Business Conduct
Susan Roberts on Creating a Compliance Program Book
Cheryl Curbeam on Creating a Compliance App
Compliance Perspectives: Simplifying the Code of Conduct
Employment Law Now IV-65- The Great Debate Part 2: Employee Lawyer vs. Employer Lawyer
Compliance Perspectives: The Impact of Workplace Loneliness
Compliance Perspectives: Compliance and Technology
Compliance Perspectives: Rolling Out New Compliance Initiatives
Podcast - Risk Mitigation & Management: Bringing a Compliance Program to Life
Day 3 of One Month to 360-Degrees of Communications in Compliance-The D&B Experience
I-17 – Engaging Your Employees in Today’s Workplace, Featuring Rick Turner at Whirlpool Corporation
Operationalizing Compliance Through Your Tone in the Middle
Day 17 of One Month to Better Compliance Through HR-Using HR to Create an Ethical Culture
Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues
This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP). The revised guidance reflects the government’s evolving expectations regarding corporate responsibility...more
On October 21, the Securities and Exchange Commission’s (SEC’s) Division of Examinations (Division) released its examination priorities for 2025, outlining the key topics the Division plans to focus on in the upcoming fiscal...more
The Criminal Division of the U.S. Department of Justice (DOJ) recently updated its Evaluation of Corporate Compliance Programs (ECCP) policy document, which prosecutors rely on to evaluate the effectiveness of compliance...more
Every compliance program begins with a code of conduct. The code of conduct expresses a company’s fundamental values and its commitment to living by them. Although a code of conduct is usually a very high-level document, it...more
What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action as proof of ethical overall behavior....more
The Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have repeatedly emphasized the importance of aligning compensation plans with compliance goals. According to Tom Fox, aligning the compensation...more
Background Note: In their analysis of the Foreign Corrupt Practices Act (FCPA), Adam Rouse, Vazantha Meyers, and Ashish Prasad emphasize the crucial role of robust compliance programs in minimizing liability associated with...more
Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more
How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more
Bill Yeoman died this week. You have to be a knowledgeable fan of college football to recognize that name as he retired in 1986. He was the head coach for the University of Houston (UH) Cougars for 25 years. His contributions...more
I recently had the opportunity to visit with Michele Edwards, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more
What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in...more
This presentation is for ethics and compliance professionals in the health care industry. Main Points Covered: Learn how to: Reflect industry standards, organizational culture, mission and values in your Code Build...more
When the DOJ is deciding whether to charge a company with a criminal antitrust violation, or agreeing to a deferred prosecution agreement (DPA), the effectiveness of a company’s antitrust compliance program is only one...more
In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...more
Many organizations struggle with their internal culture for a variety of reasons. Establishing a strong and compliant corporate culture is paramount for an effective compliance program, as even the DOJ has harped on in its...more
In light of the evolving (or evolved) DOJ and SEC approach to FCPA enforcement in the merger and acquisition context, global companies have to emphasize their post-acquisition process. ...more
The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more
Procedural fairness is one of the things that will bring credibility to your Compliance Program. Today it is called the Fair Process Doctrine and this Doctrine generally recognizes that there are fair procedures, not...more
I have reviewed the creation and update of a Code of Conduct this week, with a big assist from Eric Morehead, the Principal of Morehead Compliance Consulting. We reviewed the legal requirements, the suggested structure and...more
KPMG recently published its latest survey of chief compliance officers. The report highlights the increasing value of effective Compliance. It also reveals growing pains of our industry, specifically in maximizing...more
Today focus in the Code of Conduct series is on the aspect of training on your finalized Code of Conduct. Eric Morehead, Principal of Morehead Compliance Consulting, joins me in this series. While there have been criticisms...more
I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more
Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more
The FCPA Guidance states, “In addition to evaluating the design and implementation of a compliance program throughout an organization, enforcement of that program is fundamental to its effectiveness. A compliance program...more