Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a mature ethics and compliance program is whether the company assesses and mitigates its C-Suite risks. Over and over again, companies fall under government scrutiny because of misconduct in...
To promote a culture of integrity and a commitment to organizational justice, companies have to implement an effective, efficient and reliable internal investigation program. Such a system has to respond to employee concerns promptly and investigate these concerns fairly and consistently. Companies have to devote adequate resources and attention to its internal investigation program. In this episode, Michael Volkov discusses how to design and implement...
Karin Sweigart, a Senior Associate at The Volkov Law Group, rejoins us for another posting on employment compliance and litigation risks. Karin can be contacted at ksweigart@volkovlaw.com. There are many reasons to have an employee manual or handbook can be good for your business. Employee manuals help set expectations, provide guidance on how to handle conflicts, and, when drafted and implemented correctly, can protect your...
I am pleased to announce the release of my new e-book, It’s the Culture Stupid: Ethics and the Definition of Successful Companies. (Available Here). Many thanks to Corporate Compliance Insights, Maurice Gilbert, Sarah Hadden and Emily Ellis for their continuing support. I am proud to partner with such a fine organization and professional group.
Chief financial officers are powerful players in the corporate governance landscape. CFOs play a critical role in the management and oversight of the company’s internal accounting controls. Sarbanes-Oxley lifted the importance of CFOs and internal auditors as important gatekeepers. With that important role, CFOs and corporate leaders have to certify as to the accuracy of the company’s financial reports, subject to potential criminal consequences. CFOs...
When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. Petrobas has long suffered under a stigma of corruption, and as outlined in its recent settlement actions, the title was well deserved. Petrobas’ corruption was firmly coordinated and entrenched with Brazil’s political corruption. The pervasive nature of Brazil’s political and...
Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.” In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now be subject to an SEC-imposed compliance monitor. (Here). Stryker’s recent set of violations surrounded books and records violations and deficient accounting and compliance controls in India, China and...
Donna Boehme is our guest on this week’s podcast. She is an advocate for an independent, and empowered Chief Compliance Officer. Donna is an internationally recognized authority in the field of organizational compliance and ethics with over 20 years’ experience designing and managing compliance and ethics solutions, within the US and globally. As Principal of Compliance Strategists LLC, she has advised a wide spectrum of private,...
Traditionally, businesses were able to prepare for changes in laws and regulations in advance by monitoring legislative and regulatory actions in Washington, D.C. and relevant state capitols. Agencies would initiate rulemakings and give notice to interested parties of new or changed rules. Congress would consider legislation and it would be subject to some kind of “regular order” or process. In the “good old days,” businesses...
Webinar: The False Claims Act — Enforcement Risks and Compliance Trends Tuesday, October 10, 2018 Sign Up Here Companies in the defense and healthcare industries face significant risks from False Claims Act prosecutions and litigation. The Justice Department has an impressive record of annual recoveries totaling over $2 billion. A vibrant whistleblower community and legal practitioners create significant risks for companies in these industries. To...
