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;...
Some things are hard to define and measure in compliance. Culture is the prime example often cited by commentators. I do not share that opinion. Whether it is quantified or not, there is one unmistakable truth – you know when you have a positive culture and you know (but often try to ignore) when your company has a poor culture. When I work with companies...
You can always count on lawyers to ring alarm belles and warn businesses. The line between accurate reporting and fear-mongering sometimes blurs when lawyers write so-called “alerts” to inform businesses of new or increasing risks. When it comes to the False Claims Act, I always try to “stick to the facts.” For healthcare, pharmaceutical/medical device, and defense companies, the False Claims Act is usually the...
We all know our favorite things and people who fit together well – milk and cookies, peanut butter and jelly, chips and salsa, Tracy and Hepburn, Martin and Lewis, Abbott and Costello, and many other great combinations. In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate...
