Tagged: CCO independence

5 Telltale Signs of a Weak Corporate Culture

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the tangible benefits of an ethical culture, companies are striving to achieve such a goal. Unfortunately, there is no single solution to companies that want to establish...

DOJ’s Compliance Program Evaluation: the Role of the CCO (Part II of IV)

DOJ’s Compliance Evaluation highlights important trends in the role and independence of the Chief Compliance Officer. DOJ has stopped short of requiring direct reporting of a CCO to a CEO or other senior officer but it is inching closer to such a demand. In the topic area relating to Stature [of a CCO], DOJ lists important issues for a company to consider in designing its...

When Lawyers Cross the Line – Breaking Bad Under the Law

While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer crossing the line – from lawful to unlawful. Not only did the Embraer legal executive know about the bribery scheme, the executive was the one who came up...