News & Analysis as of

Ethics Internal Investigations

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

by Thomas Fox on

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

Lawyers Can Be A Positive Force for Compliance

by Michael Volkov on

Lawyers get a bad rap, and I am not just referring to all the lawyer jokes we have heard numerous times. Lawyers get a bad rap when it comes to compliance. Much of it is not deserved – but candidly, some of it is deserved....more

The Importance of A Robust Conflicts of Interest Program

by Michael Volkov on

It is always interesting to learn how companies handle specific compliance issues. Years ago, I could always tell when a compliance department was lacking in stature and independence in a company. Typically, I observed three...more

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

Practicing Compliance

by Thomas Fox on

It has certainly been a week for the ages in Houston, most of Texas and all along the Gulf Coast as Hurricane Harvey has wrecked a level of havoc not scene in that large a swath for many a moon, if ever. Ending this...more

5 Telltale Signs of a Weak Corporate Culture

by Michael Volkov on

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the...more

Investigation Challenges

by Thomas Fox on

Today I conclude my three-part series on internal investigations with Jonathan Marks, a partner at Marcum LLP and a well-known internal investigation expert, by considering some of the challenges you may well face during an...more

Day 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

by Thomas Fox on

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...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

Sunshine Superman – When Culture is Not My Problem

by Thomas Fox on

Today we honor folk-rocker Donovan and his signature song Sunshine Superman, which was profiled in the Wall Street Journal (WSJ) column Anatomy of a Song. The song was a love paean by the singer to “Linda Lawrence, his love...more

Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV)

by Michael Volkov on

Here is a profound grasp of the obvious – Lawyers can be difficult people. Some like to condemn the profession in its entirety (and carry with them a collection of lawyer jokes). As an attorney, I beg to differ. Many...more

5 Trends in Whistleblower Hotlines and Protections to Be Aware of in 2017

by NAVEX Global on

Every year it’s safe to assume that our list of Top 10 trends will include the latest developments pertaining to helplines, whistleblower reporting and retaliation, and this year is no exception. We begin by examining some...more

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

by NAVEX Global on

Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

When Managing Whistleblower and Retaliation Risk, Tools are Important – Processes and People are Critical

by NAVEX Global on

One collection of terms I hear a lot is “tools, processes and people.” All three need to be successfully deployed to make a compliance program run properly while also creating an organizational culture that supports...more

Match Made in Heaven: Compliance and Human Resources

by Michael Volkov on

The corporate compliance function is only as successful as its partnerships with key internal constituencies. Depending on the company and the personnel involved, compliance has to establish and maintain effective working...more

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

by Michael Volkov on

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Hallmark 8-Confidential Reporting and Internal Investigations

by Thomas Fox on

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more

Is Your Organization Prepared for Ontario Bill 132?

by NAVEX Global on

On September 8, 2016, new legislation in Ontario will go into effect requiring employers to investigate incidents or complaints of harassment or sexual harassment in the workplace. Employers with employees in Ontario will...more

Are You Leaving Whistleblowers Waiting?

by NAVEX Global on

One of the troubling findings in our most recent Ethics and Compliance Hotline Benchmark Report is that organizations are taking longer and longer to close cases, continuing a trend we’ve seen throughout this decade....more

Defining Compliance 2.0: Key Compliance Partners (Part 5 of 5)

by Michael Volkov on

I always use the “Streetcar Named Desire” line to describe the challenges a  Chief Compliance Officer faces – CCOs depend on the kindness of strangers.  It is a little bit of an exaggeration but bear with me. CCOs are not...more

[Event] 2015 Ethics & Compliance Virtual Conference - Nov. 17th, Virtual

by NAVEX Global on

Don't miss the largest ethics & compliance industry event of the year! Brand New Topics & Sessions! * Hear nine engaging sessions—including our Keynote by Governor Thomas J. Ridge—and gain practical takeaways to...more

Five Requirements for Organizational Justice

by Michael Volkov on

Ethical companies, by definition, have a robust system for internal organizational justice. A company that suffers from unequal treatment of similarly situated executives, managers, and employees cannot maintain an...more

Five Ways to Ensure Board Support for Compliance

by Michael Volkov on

A Chief Compliance Officer has a number of important relationships to maintain in an organization. Aside from the support of senior level executives, the CCO has to build an effective working relationship with the board and...more

Despite Criticism, DOJ’s New Policy On Internal Investigations Could Be a Good Thing

by NAVEX Global on

While naysayers believe the Department Of Justice's (DOJ’s) memo is going to result in major complications and headaches for companies experiencing government investigations, ethical companies are unlikely to be affected much...more

DOJ Targets Executives and Individuals in Corporate Investigations

by Holland & Knight LLP on

Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more

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