Compliance into the Weeds: A Deep Dive into Employee Leaks and Corporate Culture
The EU Whistleblowing Directive
Six Steps Companies Can Take to Manage the Risk of Using Generative AI
Helpline Usage (or Lack Thereof)
Corporate Compliance and Enforcement Hot Topics with IBM VP, Una Dean
Encouraging Internal Whistleblowers
Encouraging Employee Feedback and Internal Whistleblowing
Integrity Matters: Fraud Trends for 2022, Ep. 1
JONES DAY TALKS®: The eBay Cyberstalking Case: Mitigating the Compliance Risks of Employee Misconduct
Doing Business in the European Union | Reporting Systems and the Importance of Culture & Language
Doing Business in the European Union | EU Directive, Following Up With The Whistleblower
Susan Roberts on Creating a Compliance Program Book
Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting
In recently released updated guidance, the Antitrust Division (“Antitrust Division”) of the U.S. Department of Justice (“DOJ”) outlined how its prosecutors will assess corporate compliance programs when conducting criminal...more
A culture where employees feel safe to voice concerns through a speak-up culture, is foundational to an ethical and compliant organization. But fostering this environment is a two-way street; employees must feel both...more
In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more
The U.S. Securities and Exchange Commission’s (SEC) Whistleblower Program was created in Section 922 of the Dodd-Frank Act of 2010, which amended the Securities Exchange Act to include a whistleblower provision. It has since...more
On April 15, 2024, the Criminal Division of the U.S. Department of Justice (“DOJ”) released new guidance relating to a Pilot Program on Voluntary Self-Disclosures for Individuals, promising to offer protection from criminal...more
When was the last time your organization received an anonymous compliance concern? Has it been so long you can’t recall? Maybe you consider yourself lucky that the organization has never received a concern on your watch, or...more
I recently concluded a podcast series with Case IQ. Over this series, I visited with Sharlyn Lauby, Jakub Ficner, Kenneth McCarthy, and Meric Bloch on the different facets of a great speak-up regime and how each of those...more
We are on a run of some great, informative and incredibly useful books by some super star compliance professionals. A couple of weeks ago Mary Shirley released Level Up. In her book, Mary shared forward-thinking hacks and...more
Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more
NAVEX recently released its annual Hotline and Incident Management Report. Given NAVEX’s strong position in the hotline service market, NAVEX has access to a large volume of reporting data. As a result, its annual report is...more
On May 19, 2021, the SEC announced an award of more than $28 million to a whistleblower whose tip led the SEC and the DOJ to reach a combined $281 million FCPA settlement with a U.S.-based manufacturer of electronic systems...more
NAVEX Global produces a number of important compliance program reports. NAVEX Global always has played an important thought-leadership role in the ethics and compliance field....more
On 23 October 2019, the European Parliament and the European Council adopted the Whistleblower Protection Directive (Directive) to set a minimum standard for the protections EU member states must provide to whistleblowers. ...more
In 2019 the EU introduced new rules to enable whistleblowers to report about EU law irregularities (https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32019L1937), which EU countries must implement into their...more
Investigations & White Collar Defense - Amendment to Whistleblower Protection Act - On June 8, 2020, the Japanese Diet passed a bill to amend the Whistleblower Protection Act ("Act"). The bill was introduced amid a...more
What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin...more
The Justice Department “listens and learns” from companies and compliance practitioners. As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more
Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more
On April 23, Kramer Levin reported on the European Parliament’s approved proposal for the adoption of a whistleblower protection directive. On Oct. 7, the Directive on protection of persons reporting breaches of Union law...more
The twist and turns of our political world amid the ongoing controversy surrounding whistleblower reporting has focused attention on an important issue – encouraging whistleblowers as part of a speak up culture and...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more
Employee hotlines are – sorry about this – a “hot” topic these days in compliance. NAVEX Global’s recent study confirmed the importance of an effective hotline system. Companies that implement robust and widely-used...more
Over the past few blog posts, I have been exploring a recent article in Harvard Business Review by Gary P. Pisano, entitled “The Hard Truth About Innovative Cultures”. Pisano says the conventional wisdom is innovative...more
I have long articulated that companies that have robust compliance programs are more efficient, better run and more profitable organizations. ...more