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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
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
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
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
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 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