New compliance risks are emerging as a result of Covid-19. With new work patterns inside companies and outside, risk patterns have shifted. Yet many companies are furloughing or reducing staff dedicated to anti-bribery and anti-corruption functions, often in direct contrast to changing and rising compliance needs.… Continue Reading
Coping with the coronavirus will require enhanced vigilance by compliance teams. As boards and senior executives navigate the way forward with a focus on sustainability and financial resilience, compliance officers must ensure they remain at the forefront and visible.… Continue Reading
One of the most significant developments in the ethics space in recent years is the recognition that “paper” programs don’t afford meaningful protection against misconduct or its consequences. Established companies such as Nissan and Pacific Gas & Electric and media companies reeling from #MeToo scandals generally have a compliance infrastructure of lawyers, Codes of Conduct, training and hotlines but nonetheless their CEOs and senior managers have behaved as if these safeguards didn’t apply to them.… Continue Reading
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
How well positioned are today’s code-of-conduct practices to meet the effectiveness criteria for Corporate Compliance Programs embedded in the latest DOJ guidelines? That is, “Is the compliance program well designed? Is it being implemented effectively?… Continue Reading
But there’s something even more important and deeper than those rules.… Continue Reading
Here’s the latest FCPA disclosure from oil field services firm Halliburton Company from its Form 10-K filed with the SEC on February 7:
We are conducting internal investigations of certain areas of our operations in Angola and Iraq, focusing on compliance with certain company policies, including our Code of Business Conduct (COBC), and the FCPA and other applicable laws.… Continue Reading
Michael Scher’s post, The real code of conduct nobody mentions, brought this to mind.
In 1988 Robert Jackel wrote Moral Mazes, a ground-breaking book of corporate culture. Herein he addresses the fundamental rules of organizational life:
… Continue Reading
The discussion of a Code for Compliance Officers highlights some of the strengths and weaknesses of the compliance profession.
Consider a situation familiar to COs summarized from readers’ comments:
“I see excellent, competent COs being pushed out of compliance by other COs.… Continue Reading
A compliance professional working in China posed this question: What is the role of a compliance professional?
I answered the question in my post, The Job of a Compliance Officer is to Tell the Truth.… Continue Reading