Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to address internal operational issues. It is easy to “ignore” the importance of a positive relationship with the corporate board. A CCO who has a strong relationship with the company’s board...
Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure. Yet tone at the top is critical to building a culture of compliance – employees and managers do not live in a vacuum, they will reflect the importance of ethical business...
The next time we read about a train wreck of corporate malfeasance – be it in the anti-corruption, money laundering, financial reporting or any other space you can think of – please do not shrug your shoulders and shake your head from side to side. Instead, let’s consider how the board and senior management handled the specific matter, why they failed to address any concerns...
I have never let my schooling interfere with my education – Mark Twain (unverified). Everything has its limit–iron ore cannot be educated into gold. – Mark Twain (verified) Board members believe they know what they need to know. That is why they were asked to serve on the board. Unfortunately, like many issues today, confidence does not mean competency. Corporate boards are increasing their focus...
The VimpelCom FCPA settlement underscored the importance of Compliance 2.0 and the need to reform board deliberations and governance. No one can read the facts without shaking their heads and asking – what was the VimpelCom board thinking? The VimpelCom board’s failure to act reflects the key driving force inside the corporate boardroom – defense. When a company is not being led by the board...
Individual commitment to a group effort – that is what makes a team work, a company work, a society work, a civilization work.~ Vince Lombardi Like so many areas in life, a successful ethics and compliance program depends on teamwork. My last two postings, Parts 4 and 5, will highlight these essential partners – senior leadership and key compliance functions. In a company culture, teamwork...
Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement. Yet it is common to see a CEO who is not committed and a Chief Compliance Officer who is in denial and points to half-hearted steps to justify their own self-deception. CCOs need to take...
Webinar: August 18, 2015 1 PM to 2 PM EST Sign Up Here Companies are spending more resources on ethics and compliance programs. Department of Justice and SEC prosecutors are increasing their focus on compliance training programs to make sure they are tailored to a company’s risk profile and the company’s workforce. Compliance officers have to develop training content that is engaging and relevant to...
Some things are really clear in life – everyone knows something has to change but no one acts. Maybe it goes back to a common theme in corporate cultures – an unwillingness to stand out and instead rely on silence or what some like to call – “The GM Nod,” meaning everyone acts like they are in agreement but no one is “bold” enough to...
Donna Boehme (profile here) and I recently wrote an article — 4 Steps Corporate Directors Need to Take Toward Compliance 2.0 – which is available here. I have written about the need for corporate boards to embrace a “new reality,” reflecting the increased risks and the importance of ethics and compliance. Corporate boards can no longer rely on prior legal models to satisfy governance standards;...
