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All posts by Caterina Bulgarella

Reframing accountability to meet the new DOJ guidance

New and old corporate dishonesty stories, such as Theranos, Wirecard, and Wells Fargo, highlight a fundamental weakness. Irrespective of the industry or the business maturity, the wrongdoing escalates when the lines of defense that should protect the organization from risk become Teflon barriers to any accountability process.Continue Reading

What management model works best against the spread of COVID-19?

After reaching quasi-pandemic proportions, the coronavirus virus is a perfect example of a high conduct-risk challenge. The rate at which the epidemic will continue to spread will largely depend on how people manage the risk of contagion and whether they comply with a number of precautionary measures.… Continue Reading

Why ‘conduct risk’ is rising in UK banking

The latest Banking Standards Board (BSB) report, an executive summary of the BSB’s annual measurement of the culture in UK financial institutions, has been recently released. The report, the third since the Banking Standards Board started its measurement exercise in 2015, highlights some newsworthy findings about conduct risk in the British banking sector.… Continue Reading

Warning: Flawed Codes of Conduct can create ethical complacency

In a recent post, I shared insights from a code-of-conduct best practice study I recently conducted in collaboration with SAI Global. As noted in that post, “companies …are not neglecting all the design elements needed for the code to successfully influence the organization’s ethical orientation and culture.… Continue Reading

Caterina Bulgarella: Why customer needs sink to the bottom of institutional priorities

The Banking Standards Board (BSB) recently released the results of its second annual culture assessment across a sample of firms in the UK banking sector.

Established after the fallout of the Libor scandal as part of a larger effort to rebuild trust in the British financial system, the BSB is a private entity open to all banks and building societies operating in the United Kingdom.… Continue Reading

Caterina Bulgarella: Why good words can produce bad acts

One of the most common discussions in the ethics and compliance community today revolves around the idea of using corporate values to foster ethics in organizations. Though this conversation has helped practitioners move away from a check-the-box compliance approach, practices based on corporate values have unwittingly created a check-the-box approach to ethics, obscuring the disconnect between external values and what the organization actually values.… Continue Reading

Caterina Bulgarella: How lofty values led to Kobe Aluminum’s failures

On October 8, 2017, Kobe Steel Group admitted to falsifying data about the strength and durability of aluminum and copper parts used by manufacturers of automobiles, bullet trains, and aircraft.

Initially presented as a breach occurring at four of its Japanese factories during 2017, the admission of wrongdoing would soon turn into a much more severe affair. Continue Reading