Tagged: corporate culture

Episode 204 — “This is the Way” on Corporate Culture

The culture bandwagon is picking up steam.  Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations.  In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies continue to cite the importance of a company’s  “culture of compliance.” But when it comes to defining the terms, how to...

Practical Approaches to Managing Culture: Defining the Organization’s Mission (Part I of IV)

The culture bandwagon is picking up steam.  Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations.  In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies, continue to cite the importance of a company’s  “culture of compliance.” But when it comes to defining the terms, how to...

Watching a Slow Train Wreck – Culture Breakdowns Step-by-Step

A corporate scandal does not occur overnight. (Thank you Bob Dylan). A CEO does not begin the day telling him or herself that today is the day to begin the Ponzi scheme or complex fraud.  It is hard to imagine but corporate scandals grow from itsy-bitsy steps to bigger risks, and eventually to the full corporate embrace. (Thank you Three Stooges, “Slowly I Turned”).  Along...

Corporate Culture: Health and Safety (Part II of II)

Companies face a daunting challenge to reassure and regain trust and integrity with employees.  CEOs should view the current situation as an opportunity to improve a company’s culture by building on the company’s trust and integrity values. Aside from basic economic questions, companies have to ensure that employee health and safety are assured.  In this pandemic era and with the spread of disinformation by politicians,...

Corporate Culture: Leadership (Part I of II)

Companies are under enormous stress given the pandemic and the social unrest.  Employees are looking to companies to provide some sense of stability and ultimately leadership.  Corporate leaders are being tested and it is clear that in this defining moment, some will rise and some will fail.  It is pretty obvious whether a CEO can meet this challenge. Perfunctory and happy-talk emails or positive messaging...

What Happens When Managers Misbehave?

Company managers are the lynchpin of a corporate compliance program.  Without belaboring the Tinkers to Evers to Chance baseball analogy, a corporate culture of compliance requires an important information and accountability flow (or cascade) from leadership to senior managers to on-the-ground managers.  It is at this level that the compliance message requires effective communications and conduct by managers directly to employees.  This is where the...

Five Signs Your Company Lacks Integrity

It is always easy to second-guess or look back with 20-20 hindsight on a compliance breakdown and point out all the problems that were ignored or created by corporate actors.  There are common factual scenarios that recur in DOJ and regulatory enforcement actions, some of which fall into certain categories.  While defense counsel (being effective advocates) often argue that bad actors are often “rogue” employees,...

Touting Corporate Culture to Excuse a Commitment to Compliance

There is no question that corporate leaders, senior executives, legal and compliance staff, and internal auditors recognize the value of an ethical corporate culture.  It is the latest “fad” in corporate governance, and it is a welcome development.  I have written extensively on this important trend and the value of a company’s culture of ethics and compliance. CEOs and corporate executives, however, have embraced this...

Corporate Doublespeak: A Bribe is a Bribe

Language communicates more than just words – indeed, the use of language reflects much more than simple communication.  Often, a person’s language reveals an attitude, a feeling, a perspective, and much more about a person.  To me, I am often struck how language is used by corporations to mask a clear and distinct idea.  Corporate speak is a language unto itself, and can reflect a...

The Culture Bandwagon — SEC Chairman Joins the Club

Maybe I am missing something, but everyone is jumping on the culture bandwagon.  Regulators like to speak about it; prosecutors like to emphasize it – everyone likes to talk about it as a way to encourage corporate leaders to commit to promoting an ethical culture. Let’s face it – talking about culture is an easy way to demonstrate your commitment to ethics and to compliance...