Believe it or not, life principles can be used in compliance, especially in due diligence. I always tell my kids that life has a way of setting priorities. As you get older, life becomes simpler and your priorities become clearer. Now watch this transition – the same goes for due diligence, not the age part but the priorities part. Once you assemble information and data...
He that can have patience can have what he will. – Benjamin Franklin Putting together an effective due diligence system requires patience. I freely admit that I am not a patient person, especially when it comes to ensuring ethics and compliance. By definition, however, effective compliance strategies require patience due to the scope and scale of the changes being implemented across a company. Due diligence is...
Webinar: Compliance 2.0 — A New Model for Ethics and Compliance Programs Tuesday, November 10, 2015, 12 Noon EST Register Here In the last year, ethics and compliance leaders have been describing a new model for ethics and compliance programs, referring to it as “Compliance 2.0.” For compliance professionals, Compliance 2.0 includes a number of important principles relating to the role of the Chief Compliance...
This week I am posting a series on due diligence. Also, I just released a new e-book on due diligence which can be downloaded here. There are basically two types of people. People who accomplish things, and people who claim to have accomplished things. The first group is less crowded. – Mark Twain In a former life (or even present life), Mark Twain had to...
As a federal prosecutor with lots of trial experience, I generally know what questions to ask a witness or a defendant. In the compliance arena, there is much more leeway in how and what questions you ask. Many companies conduct employee surveys. These surveys are usually administered by human resources across the organization every year or two. I do not oppose these surveys but recommend...
Integrity has no need of rules. – Albert Camus Corporate decision-making ignores important principles and sometimes, common sense. With the increase in corporate compliance programs, corporate boards and senior executives need to take a moment to address one important issue – the importance of creating an ethical culture. For some reason, corporate boards and leaders like to focus on the tangible aspects of ethics and...
NAVEX Global, Regulatory Data Corporation, and The Volkov Law Group invite you to attend a half-day meeting to discuss Third Party Risk Management: New and Innovative Strategies, on November 5, 2015, 12:30 pm to 6 pm in Silicon Valley. Please Sign Up HERE. We look forward to seeing you at the meeting. The half-day forum will bring together senior ethics and compliance professionals for a...
In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct was occurring or could occur? Second, how did the wrongdoers obtain access to the money needed to fund the bribery scheme? I know these two questions are fairly obvious, but...
The Justice Department’s recent Yates memorandum on individual accountability is a significant event. Sure, you can always find members of the FCPA Paparazzi who will discount the memo, or relegate it to a mere “political” statement. That view is unfortunate and ignores the real implications of the Yates memo. Such a viewpoint also shows how little members of the FCPA Paparazzi understand the true inner...
Ethical companies, by definition, have a robust system for internal organizational justice. A company that suffers from unequal treatment of similarly situated executives, managers, and employees cannot maintain an ethical culture. Unequal justice will undermine employee morale, reporting of misconduct, and overall productivity rapidly. Cynicism breeds contempt, and there is nothing like employee discontent when it comes to the sustainability of corporate productivity. To ensure...
