code of conduct Archives - Corruption, Crime & Compliance

19 Apr, 2023

U.S. and International Partners Unveil New Code of Conduct Respecting Human Rights Concerns in Relation to Export Control Measures

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...

Uncategorized

8 Jul, 2018

Episode 46 — Implementing a Policy Management Program

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...

General

14 Dec, 2016

Code of Conduct Training – Now What?

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...

Uncategorized

11 Dec, 2016

The SEC’s Continuing Refinement of Internal Controls Enforcement

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...

General

9 Nov, 2015

Does Training + Code of Ethics = Culture of Ethics?

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...