The Reality of Compliance: The Individual Employee

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2 Responses

  1. The rate of overall economic and moral decline (DOJ lets Goldman go free), eroding protestant ethic amidst bloated financial sector which does not abide by it but by greed alone heavily contribute to further lowering of moral anchors for being ethical and compliant. This backdrop affects people more than internal ethics and compliance hooks that try to keep employees in line.

  2. Donna Boehme says:

    You’ve nailed it again. Sure, individuals commit acts of bribery but that completely overlooks the environment that makes that possible or even probable. It also overlooks the colleague who sees the bribery and then decides to report it because of that environment. That’s what compliance programs are all about. General counsels who make statements like that are Exhibit A for why they should not be in charge of compliance. They should keep their day jobs and let the CCO do her job. They should also read David Gebler’s book on The Three Power Values on the impact of culture on individual actions or my column on the role of the CCO
    Either way, we need fewer GC’s trying to run compliance based on outdated notions through a purely legal lens and more empowered, independent CCOs who know what they are doing. That’s my 2Cents for the day.