This is a topic that every compliance professional has to address in one form or another. Chief compliance officers are so busy that they often cannot even take the time to tackle this difficult issue. This is a real practical issue of importance. Just to define terms and the focus of this blog posting — we have to define the issues and purposes of the...
Chief compliance officers are often responsible for managing a company’s conflicts of interest policy. A company can suffer serious legal and reputational harm if it fails to identify and mitigate conflicts of interest. The nature and scope of conflicts of interest vary across the organization, especially at senior management and board levels. Given the number and complexity of conflicts, CCOs have to devote adequate attention...
Webinar: Conflicts of Interest — Effective Strategies to Mitigate Risks Wednesday, October 16, 2019 12 Noon EST Sign Up HERE Chief compliance officers are often responsible for managing a company’s conflicts of interest policy. A company can suffer serious legal and reputational harm if it fails to identify and mitigate conflicts of interest. The nature and scope of conflicts of interest vary across the organization,...
In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk assessments. ISO 37001 requires companies to conduct regular risk assessments in order to identify the bribery risks the company might reasonably anticipate; analyze, assess and prioritize the identified bribery risks; and evaluate...
It is always interesting to learn how companies handle specific compliance issues. Years ago, I could always tell when a compliance department was lacking in stature and independence in a company. Typically, I observed three important indicators – a compliance department that was stuck in the legal department reporting to the general counsel; mired in detailed gifts, meals and entertainment reviews and approvals; and devoted...
