News & Analysis as of

Discipline Compliance

Farewell to The Hawk – Fair and Consistent Application of Discipline

by Thomas Fox on

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

by Thomas Fox on

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Day 21 of One Month to Better Compliance Through HR-the HR Gap Analysis for Compliance

by Thomas Fox on

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

Operationalizing Compliance Through Your Tone in the Middle

by Thomas Fox on

One of the ways that Human Resources (HR) can help to operationalize compliance is to assist each level of an organization to have a proper tone. While the top of an organization rightly gets much of attention, the tone about...more

Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine

by Thomas Fox on

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

Day 7 Of One Month To Better Compliance Through HR - Six Principles For Compliance Incentives

by Thomas Fox on

In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives. She posed it with the following question, “Are there mechanisms to enforce compliance...more

New Guidance from the DOJ on Your Compliance Program

by NAVEX Global on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

Hallmark 6-Incentives and Disciplinary Measures

by Thomas Fox on

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

Ten Hallmarks of an Effective Compliance Program-Hallmark 6

by Thomas Fox on

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 6-Incentives and Disciplinary Measures....more

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose

by Thomas Fox on

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

The Chicken Or The Egg?

by Fisher Phillips on

You finally decided to take the long overdue disciplinary action. Jack has got to be disciplined. But just before you do, Jack, possibly sensing what’s about to happen, makes a complaint of harassment. This is the first...more

Three Keys To An Effective Disciplinary Program

by Michael Volkov on

The Justice Department and the SEC have underscored the importance of a company maintaining a clear disciplinary process so that executives, managers and employees are aware that a violation of the corporate code of conduct...more

Establishing an Effective Compliance Program: An Overview to Protecting Your Organization

by Holland & Knight LLP on

In This Issue: - Overview - Standards and Procedures - Organizational Leadership and Culture - Reasonable Efforts to Exclude Bad Actors From Managerial Ranks - Training and Education - Monitoring,...more

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