Everything Compliance - The Elon Etc Edition
Salvador Dahan on the Journey of Petrobras
Susan Roberts on Creating a Compliance Program Book
Across the Board – Episode 1: What’s the Tone at the Very Top
Compliance into the Weeds: Episode 117-Wells Fargo Update
Podcast: Common Risks and Challenges in Running a Global Ethics & Compliance Program
Legal Risk Management Forum: panel highlights
The Compliance Challenge: Managing Legal & Regulatory Risk
Episode 22: Social Impact Programs: Why Purpose Makes a Difference
COMPLIANCE INTO THE WEEDS-EPISODE 45, THE UNDESERVED PRIVILEGE EDITION
Compliance Into the Weeds-Episode 42, the Uber Edition
Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance
Day 20 - Compliance Leadership from the Bottom
Operationalizing Compliance Through Your Tone in the Middle
Day 1 of 30 Days to a Better Compliance Program, Tones in an Organization
Ten Hallmarks of an Effective Compliance Program-Hallmark 1
This week we have been exploring how Chief Executive Officers and other senior executives can set an appropriate Tone at the Top by actually walking-the-walk of compliance rather than simply talking-the-talk of compliance....more
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
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
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
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
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
There are a lot of talented CEOs. Some remarkable leaders, innovators and eloquent spokespeople for their companies. In several recent experiences, I have been befuddled by some CEOs....more
We often hear the compliance refrain on the importance of tone-at-the-top – meaning when the board, the CEO and senior executives demonstrate by communications and by conduct their commitment to a culture of ethics and...more
The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more
I continue my exploration of how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J....more
Think about the task facing new Uber Chief Executive Officer (CEO), Dara Khosrowshahi. He is working to overhaul a toxic corporate culture, while dealing with regulators literally across the globe. ...more
In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more
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
The key concept from the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Program (Evaluation) is operationalization. For instance, under the query Shared Commitment is the following question - “How is...more
In a previous blog post, I promised to release a list of questions a Board of Directors (Board) might ask its compliance officer. This post is intended to fulfill that promise. My intent is to help Board members exercise...more
Today, I wanted to consider some of the recent leadership lessons I have explored on my podcast, 12 O’Clock High, a podcast on business leadership. In the series, host Richard Lummis and myself, mined some of our favorite...more
In an unusual move, the Justice Department issued an important document in the dead of night – Evaluation of Corporate Compliance Programs. We have no explanation from the Justice Department for the issuance of this...more
Last summer I ran a two-week, combined blog and podcast series on the Ten Hallmarks of an Effective Compliance Program. The series was quite well received. As I fancy myself the Nuts and Bolts compliance guy and inspired an...more
We all tend to gloss over a critical requirement for an effective ethics and compliance program – tone-at-the-top. I hate to be dogmatic about the issue but, as Mel Brooks said in the Curb Your Enthusiasm (Season 4, Episode...more
Sir Neville Marriner died on Sunday. For any aficionado of classical music, Marriner’s contribution to the genre was immense, having founded the chamber orchestra, Academy of St. Martin’s in the Fields in 1958. The group was...more
I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more
The U.S. Securities and Exchange Commission (SEC or Commission) issued a cease and desist order (Order) on June 23, 2015, against Pekin Singer Strauss Asset Management Inc. (Adviser), an investment adviser registered under...more