When you look at the core of several major financial scandals, it is easy to point to problems with sales incentives and corporate culture. A company can rapidly grow due to the extraordinary performance of a company’s sales culture. In many cases, this sales culture creates real and significant risks for misconduct. To address such potential for misconduct, companies rely on internal controls to constrain...

The Road to Hell is Paved with Good Intentions – Samuel Johnson, 1775. You can draft and design the best ethics and compliance program – and then fail.  You can show every compliance professional an “effective” set of ethics and compliance controls, pristine, drafted elegantly, addressing each and every risk with the perfectly calculated impact, and your program may fail.  Why? Paper compliance programs are...

Company managers are the lynchpin of a corporate compliance program.  Without belaboring the Tinkers to Evers to Chance baseball analogy, a corporate culture of compliance requires an important information and accountability flow (or cascade) from leadership to senior managers to on-the-ground managers.  It is at this level that the compliance message requires effective communications and conduct by managers directly to employees.  This is where the...

Chief compliance officers face a mountain of tasks – it is easy to get overwhelmed.  Add to the mix the fact that CCOs are under extraordinary pressure to “prevent and detect” potential violations of the company’s code and any law or regulation.  When you think about it, that is quite a heavy responsibility. In the ebb and flow of ethics and compliance ideas, one constant...

If you are a fan of Simon Sinek, you will understand and probably agree with the thrust of this posting. Sinek is a great motivational and business speaker. Many of his observations are spot-on and I would urge you to review some – here are some samples (here, here, here, and here). Getting back to the importance of accountability in a corporation, let’s start with...

Everyone likes to give advice on the importance of tone-at-the-top. Like many things in life, it is easy to talk about but much more difficult to implement. There are lots of ways to describe or analyze the same issue. In the end the result has to be reached. To boil it down, tone-at-the-top requires leadership. That is pretty obvious. But, what kind of leadership? This...