LRN consistently provides high-quality reports and important insights on ethics and compliance trends. Each year, LRN’s Program Effectiveness Report is anticipated as an important source of cutting-edge ethics and compliance initiatives. LRN’s Code of Conduct Report includes a number of important benchmarks for companies to use as a measure of their compliance programs. In its most recent report, LRN cites a number of important findings...
Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a posting on the recent international adoption of a human rights code of conduct. Alex can be reached at [email protected]. On March 30, 2023, the United States Department of State announced the adoption—in conjunction with a host of international partners—of a specific Code of Conduct related to human rights considerations in the context...
Companies have to implement a robust policy management program. In today’s risky environment, companies should automate a robust policy management program that requires regular review, assessment and updating of policies and procedures. A policy management program should be created consisting of key constituencies to ensure that policies and procedures are current, effective, and appropriately tailored to the company’s risk profile. In this episode, Michael Volkov...
When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of conduct and following up with robust training programs to emphasize the importance of a company’s code of conduct. That is all well and good. But it is really only the beginning...
My good friend and colleague, Tom Fox, has written an interesting post (here) on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement theory is that United violated its Business Code of Ethics (and Continental’s Code of Ethics, which was in force in 2011 as well), resulting in the failure to...
Complacency in compliance is a cancer on a company’s culture. Woody Allen said it best in Annie Hall: A [compliance program] relationship, I think, is like a shark. You know? It has to constantly move forward or it dies. And I think what we got on our hands is a dead shark. Here is the video clip of the scene: here When a Chief Compliance...
