I have a pet peeve in the compliance world. It may be symbolic; it may be petty at the same time; and it may just be a function of my old(er) age. I apologize in advance for this posting, i.e. this rant. Call it my moment on the front lawn yelling at passing cars in the neighborhood. My moment of frustration. Let’s start with two...
Forgive me for the title of this posting – I am trying to make a point; a rather obvious one. I confess I did not take philosophy classes in high school or college. So, I may have missed the boat on this issue. But from my limited vantage point with respect to the compliance industry, everyone needs to take a breath and reevaluate their use...
This week I am examining in a four-part series the issue of business ethics in an attempt to provide practical approaches to business ethics to help build and promote a company’s culture. As more attention is paid to the importance of an ethical culture, I wanted to first offer some general observations. The field of business ethics is thick with definitions, moral arguments and theoretical...
While reading the independent directors’ report on the Wells Fargo sales incentives scandal, you will be overwhelmed by the feeling of frustration. At the same time, what is described in the report is the extent to which every control function came up against the problem staring them in the face – Wells Fargo’s sales incentive program was out of control. Notwithstanding the 20-20 hindsight pictured...
It is important to remember that companies are required to implement an ethics and compliance program. Ethics should not ever be a segregated issue carved off from a compliance program. They walk hand-in-hand, and reinforce each other at every step of the mission. This is an important point and easily ignored. Compliance professionals often appoint a Chief Ethics Officer, separate from a Chief Compliance Officer,...
Everyone likes to cite and talk about the list of horrible scandals. Whether it is Enron, WorldCom, Siemens, GM, VW, Wells Fargo, we pick through the details, cite failures and use it as a springboard to a discussion of higher ideals and performance. Call it a reminder of worst-case scenarios. The rise in the chief compliance officer is based on the need for corporations to...
When looking through the wreckage of a major corporate compliance disaster, it is relatively easy to spot the important events when business needs (or money) are consciously elevated over compliance concerns or even reputational risks. It is easy to spot the circumstance, and with perfect hindsight announce to everyone (assuming someone is listening) that you would not have followed that course of action. In the...
As everyone knows, I am an advocate for promoting and maintaining a company’s culture of ethics and compliance (not compliance and ethics). The best investment a company can make is to create and maintain a positive commitment to an ethical culture. I often repeat myself (just ask my wife and kids), but a culture of ethics is far more important than well-designed and effective policies...
