Over the years one thing I have noticed is that people who have done compliance and ethics work have actual stories about getting calls from employees, or talking with them at training, or dealing with helpline calls, where we know our work has helped head off a violation.
But the outside skeptics who have studied the field somehow seem disconnected from this on-the-ground reality.… Continue Reading
In prior posts for the FCPA Blog, I discussed how compliance officers are subject matter experts for the compliance program and why the board-adopted company code of ethics is a fundamental ingredient of the compliance program.… Continue Reading
I’ve been attending the HCCA’s 19th Annual Compliance Institute this week in Lake Buena Vista, Florida.
My thanks to Professor Andy Spalding and his students from the University of Richmond School of Law for undertaking the Rio 2016 project and executing it with dedication and enthusiasm.… Continue Reading
The compliance profession has for years been beset by a debate with the outside world over the position of Chief Compliance and Ethics Officer (CECO).… Continue Reading
To balance the excitement over recent reports of the DOJ’s tough investigation and a new CEO at Wal-Mart, we could consider what compliance officers are taught by the SCCE: Lawful but awful does not mean everything is OK; it’s a wake up call and a test of the company’s identity.… Continue Reading