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
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 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
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
I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more
The Department of Justice raised the stakes in spoofing enforcement actions by including racketeering charges in an indictment filed last week alleging spoofing by three traders over many years. The Commodity Futures Trading...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
Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...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
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
Earlier this week a most interesting non-Foreign Corrupt Practices Act (FCPA) bribery and corruption enforcement, actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit...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
The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and...more
In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more
As 2015 draws to a close (where did the time go?), the 2016 planning season is in full swing. You likely already have an idea of initiatives you’ll want to tackle, but taking your ethics and compliance program to the next...more
On this day in 1982, the fabled Dalton Gang rode into Coffeyville, Kansas, supremely confident in its ability to simultaneously rob two banks in the town. When the dust settled, four of the five gang members lay dead. The...more
Welcome to Part I of Social Media Week. I recently did a webinar, hosted by The Network, on the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program. The response was as great as almost any...more
I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “Understanding the World’s Greatest Structures:...more
I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more
CME Group Summarily Suspends Trading Privileges of Two Traders Without Hearing for Alleged Spoofing and Non-Cooperation - Less than two weeks after civil and criminal charges were filed by the Commodity Futures Trading...more
On this day, 62 years ago, “The Mousetrap”, a murder-mystery written by Agatha Christie, opened at the Ambassadors Theatre in London. The crowd-pleasing whodunit has become the longest continuously running play in history,...more
For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more
It was once observed that all western philosophy is but a mere footnote to the works of Plato. However others believe that his student Aristotle merits equal standing....more