Tagged: board oversight of compliance

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance? What was the company’s culture and what steps did the Board and senior management take to implement and monitor an effective ethical culture? After reading the Airbus’ factual proffer,...