Helpline Usage (or Lack Thereof)
What's Going on With Whistleblower Lines
Whistleblowers: Don't Drink the Government's Kool-Aid
Andy Dunbar and Nick Morgan on What the SEC Expects from Your Internal Investigation
Compliance into the Weeds: Episode 118-Hotline Metrics
Compliance into the Weeds-Episode 40, COSO ERM Framework Update
Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance
Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas.[i] In issuing the new document...more
I interviewed Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), on his recently released paper, co-authored with Stephen Stubben, Associate Professor from The University of Utah, entitled “Evidence on...more
Take a look at the contexts of the top-10 FCPA fines of all time and you will soon spot a trend: mostly European-based organisations where corrupt activity has been uncovered within the day-to-day running of the business....more
I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more
Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for...more
“A culture of ethics ties long-term performance to the interests of long-term stakeholders.” — Larry Fink, Chief Executive of Blackrock The quote above was mentioned by Timothy Erblich, CEO of Ethisphere, at the...more
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
Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more
FCPA settlements carry with them a basket of compliance and enforcement lessons. The recent Goodyear settlement with the SEC for $16 million carries some important compliance and strategic reminders for ethics and compliance...more