I am pleased to announce my affiliation with NAVEX Global, and the issuance of a white paper – A Holistic Approach to Global Anti-Corruption Compliance, which is available here. There is no other company (or brand) which carries as much weight in the compliance field – NAVEX Global is a true leader, committed to professional technology solutions for ethics and compliance. NAVEX is the gold...

The most permanent lessons in morals are those which come, not of book teaching, but of experience — Mark Twain The most effective ethics and compliance program starts with a CEO.  But that is not the end of the story.  Life is easier with a CEO who understands the importance of ethics and compliance, promotes it as a financial driver for profitability and sustainability, and...

Who is responsible for developing a company’s culture?  The CEO or the CCO? That is the question, right?  As Warner Wolf, the famous sports broadcaster used to say, “Wrong!!” In fact, the answer breaks down to two-parts: (a) defining the company’s culture; and (2) communicating and embedding the company’s culture. The CEO defines the company’s culture.  In most cases, the CEO’s definition of culture reflects...

Forgive me for starting with a rhetorical question and for another in my series of profound grasps of the obvious. The answer, as we all know, to the posed question is a resounding yes.  Without getting into the details (which I will do below), ethical companies are more profitable for numerous reasons – employees are more productive; employees are less likely to leave a company;...

The art of internal investigations is the ability to identify risks, adapt to those risks and avoid knee-jerk solutions.  There are lots of nuances to internal investigations issues and the best practitioners in this area are able to identify them and carefully resolve questions. Since the stakes are high in most internal investigations, companies have to recognize the need for careful deliberation on important issues....