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Tone At The Top

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 3-Email as a Strategic Compliance Tool

We continue our exploration of how CEOs and senior executives are uniquely positioned to drive home the importance of ethical behavior and adherence to compliance regulations. Today, we consider the humble email and how it...more

Thomas Fox - Compliance Evangelist

Tone at The Top Week: Part 2 – Ten Things A CEO Can Do

In corporate compliance, a guiding principle is the foundation for success or failure: Tone at the Top. This phrase encapsulates the role of senior executives—particularly the CEO—in setting the ethical standards, cultural...more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Moving Compliance Tone Down Through an Organization

Mike Volkov, in a blog post entitled, Mood in the Middle Versus Tone at the Top, said, “Even when a company does all the right things at the senior management level, the real issue is whether or not that culture has embedded...more

NAVEX

State of R&C Report Key Finding — Mid-Level Management Shows Inconsistent Commitment to Compliance

NAVEX on

Ethics and compliance are two sides of the same coin. Compliance is following the law, while ethics is doing what is right regardless of what the law says. Compliance is typically thought of as something required by the...more

The Volkov Law Group

Making Corporate Culture a Reality: Define and Embed (Part I of III)

The Volkov Law Group on

Everyone has jumped on the corporate culture bandwagon.  For some new converts, they like to espouse corporate culture as a recent discovery, or a new-fangled approach for compliance programs....more

The Volkov Law Group

Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of...

The Volkov Law Group on

If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class.  Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more

Jaburg Wilk

Building Effective Leadership

Jaburg Wilk on

In almost any aspect of life—whether personal or professional—we work with other people where we embody many different roles. Of those, one of the most influential roles one can step into is being a leader. We are told to...more

Society of Corporate Compliance and Ethics...

[Event] 11th Annual European Compliance & Ethics Institute - March 20th - 22nd, Amsterdam, Netherlands

In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more

Thomas Fox - Compliance Evangelist

Everything Compliance - The Elon Etc Edition

Welcome to the only roundtable podcast in compliance. In 2021, Everything Compliance was honored by W3 as a top talk show in podcasting. In this episode, we have the quintet of Jay Rosen, Jonathan Armstrong, Jonathan Marks,...more

Society of Corporate Compliance and Ethics...

Salvador Dahan on the Journey of Petrobras

Operation Lava Jato (Carwash) had a profound effect on business in Brazil, with countless companies caught up in one way or another in the corruption scandal. State oil company Petrobras was no exception, but, as is the case...more

The Volkov Law Group

The CEO Sets, Defines and Manages a Company’s Performance and Culture

The Volkov Law Group on

We always read about the superstar CEO.  The company’s leader who is paid millions and is the rock star of business success.  Board members, shareholders and stakeholders support the leader because he/she has brought...more

Cadwalader, Wickersham & Taft LLP

Diversity in Fund Finance: ‘Boundary Breakers’ Recap

The Diversity in Fund Finance group hosted the second Boundary Breakers speaker series event this week, featuring a discussion with Värde Partners on the endless battle for diversity. This conversation, moderated by Alex...more

Society of Corporate Compliance and Ethics...

Susan Roberts on Creating a Compliance Program Book

Cataloguing everything your compliance program does isn’t easy, but Susan Roberts, who recently retired from full-time corporate life after serving as Chief Compliance Officer at three different companies, did just that. And...more

Morgan Lewis

Strategies for Maintaining Good Workplace Culture

Morgan Lewis on

Firm culture is under ever-increasing scrutiny and is widely considered to be at the heart of the most serious employee misconduct and ethical lapses. Senior management should lead by example and ensure a good culture is...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

You need to set the tone

I’ve been involved with so many small organizations both profit and non-profit in one form or another as an employee, officer, or client. The one thing that is consistent with each organization is that the leadership sets the...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

Dechert LLP

Ensuring Your Compliance: Lessons From Commerzbank London

Dechert LLP on

On 17 June 2020, the London branch of Commerzbank AG (“Commerzbank London”) was fined £37,405,400 by the Financial Conduct Authority (“FCA”). The FCA’s fine against Commerzbank emphasises a continued focus on Anti-Money...more

Akin Gump Strauss Hauer & Feld LLP

What Audit Committees Can Do to Prevent Accounting Fraud in Uncertain Times

- The COVID-19 crisis creates heightened risk of improper financial reporting. - Audit committees can and should take steps to help prevent such frauds. - Audit Committees should maintain the appropriate tone at the...more

The Volkov Law Group

The Coronavirus Pandemic: A Call for Leadership

The Volkov Law Group on

We need leadership from our President and our federal government.  Instead of appearing for self-congratulatory press conferences, and pushing responsibilities to state and local governments, the White House needs to direct a...more

The Volkov Law Group

The Impact of a New CEO

The Volkov Law Group on

Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations.  Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 1 – It’s Even Worse Than Imagined

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

NAVEX

Organizational Trust Is in a Perilous Place Right Now

NAVEX on

The global communications firm Edelman published their annual Edelman Trust Barometer in January. As usual, the report gave ethics and compliance officers much to consider, not all of it good. The Edelman report is a...more

Thomas Fox - Compliance Evangelist

Tribute to The Boys of Summer and Toxicity in Houston

The Houston Astros sign-stealing scandal filled out quite a bit last week with two significant new items. The first was an interview on the MLB Network by Tom Verducci, of disgraced Astros manager A.J. Hinch (Hinch...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Chairman and Senior Staff Members Share Key Reminders for Audit Committees

In December 2019, U.S. Securities and Exchange Commission (SEC) Chairman Jay Clayton, SEC Chief Accountant Sagar Teotia and Division of Corporation Finance Director William Hinman jointly issued a statement (Statement)...more

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