Tagged: accountability

21 Apr, 2023

Promoting Your Corporate Culture – Accountability and Messaging (Part II of III)

As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture. In these situations, employee misconduct rates increase, wrongdoing and scandal surround the company, and corporate leaders ultimately fall from failing to sail the corporate ship in the right directions. There are tell-tale signs of...

General

3 Nov, 2022

Board Director Accountability

We constantly hear about the importance of “accountability,” meaning that organizations and individuals have to be held accountable for misconduct or failures to act. The focus on accountability is a positive trend, consistent with our ideas of justice and fairness, Within an organization, accountability is a cornerstone of organizational justice. When demands for accountability reach the board room and individual board members, however, there are...

General

13 Apr, 2022

DOJ Raises Stakes on Corporate Compliance Programs – Accountability and Certifications

The Biden Administration’s Department of Justice has promised aggressive white collar enforcement. On the flip side, the DOJ has recognized the importance of effective ethics and compliance programs. In an interesting speech, the Assistant Attorney General of the Criminal Division, Kenneth Polite, delivered an important speech on ethics and compliance programs. AAG Polite’s speech reiterated the importance of the Justice Department’s 2020 Evaluation of Corporate...

General

27 May, 2021

Finding the Right Balance: Sales Incentives and Internal Controls

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...

General

15 Apr, 2021

Where There is No Will, There’s No Way: The Bottom Line for Chief Compliance Officers

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...

General

20 May, 2019

What Happens When Managers Misbehave?

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...

General

30 Oct, 2018

Speak Up is Great – Is Anyone Listening?

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...

General

23 Aug, 2017

Infusing Corporate Culture with Accountability

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...

Uncategorized

9 Sep, 2015

The Two Essential Requirements for Tone-At-The-Top

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...