Tagged: Corporate Governance

Trust and Integrity: The Value of a Company’s Reputation

Warren Buffet, the Oracle of Omaha, understands the importance of corporate culture and adhering to a code of ethics. He has been quoted: Lose money and I will forgive you. Lose even a shred of reputation and I will be ruthless. …… Wealth can always be recreated, but reputation takes a lifetime to build and often only a moment to destroy. Buffet’s implicit message is unmistakable – culture, reputation and...

Webinar: CCOs and the Board of Directors: Establishing an Effective Relationship

Webinar: CCOs and the Board of Directors: Establishing an Effective Relationship May 24, 2016 12 PM EST Register Here Chief Compliance Officers have to establish a positive and productive working relationship with the corporate board of directors. An effective reporting relationship is essential to ensuring an effective ethics and compliance program.  CCOs have to attend to this relationship, learn how to use it effectively, and...

Getting Back to Basics: CCOs and Independence

Chief compliance officers continue to enjoy these heady days – salaries are up and new opportunities are popping up in the corporate world. CCOs have to keep their eye on the ball. It is well and good to get a good salary, a nice office, and a title, but there is an important requirement that cannot be overlooked – independence. The trend over the last...

Fixing a Sour Corporate Culture: Valeant Pharmaceuticals Faces an Uphill Challenge

Like the Greek mythology character Sisyphus, Valeant Pharmaceutical is attempting to atone for its sins and turn its corporate culture around. I am not usually a cynic but when I see these transparent attempts to reverse a company’s culture, I have a degree of suspicion. In recent weeks, Valeant took the following steps: Hired a new CEO Joseph Papa Removed five directors from its board...

CCOs: Living in the Land of False Promises

We all have heard the scenario involving a compliance professional. A new CCO joins a company with promises from the board, the CEO and senior executives of cooperation, compensation and support for a robust independent compliance function. The new CCO arrives with an idealistic spirit only to discover that he or she has been misled. Sure, the CCO has a title, and a nice salary,...

Your Company’s Compliance Program is Finished – April Fools

Happy April Fool’s Day! Could you ever imagine coming to work one day and realizing that you have “finished” your ethics and compliance program? There is nothing left to do. You can go home. Ohhhh, if only it was so. We all know the truth – a compliance program is never finished, never completed and there is always something to do. This gets us back...

Misconduct in the C-Suite: SEC Settles FCPA Case with CEO

The SEC is setting its sights on individual prosecutions. Both the Justice Department and the SEC have reiterated the importance of prosecuting individuals. DOJ’s Yates Memorandum promises to deliver an increase in civil and criminal prosecutions. The SEC is delivering on its stated goal of increasing individual prosecutions. In a busy FCPA enforcement week, the SEC settled the SciClone Pharmaceuticals case and a separate prosecution...

The Dangers of Quick Fix Solutions – Certifications and Compliance Defenses

When the going gets tough, the tough do not necessarily get going. This is evident in the world of corporate governance, compliance, and defense against aggressive government enforcement. Corporate lobbying interests are pushing a new and dangerous agenda, one that is shortsighted and certain to create problems for chief compliance officers. Several years ago the Chamber of Commerce launched an attack on FCPA enforcement with...

Four Compliance Trends and Challenges for 2016

As we close out the year, it is now time to begin the retrospective reviews and predictions for the New Year. I will try to keep them to a minimum but I find it important to reflect and look forward to new challenges. Compliance is a fast moving profession. More attention is being paid to the compliance function, and more companies are embracing the importance...

Due Diligence and Beyond — Balancing Competing Priorities

DOJ’s compliance counsel, Hui Chen, pronounced this year as the compliance year of third party due diligence. This has been a good year for compliance, but I would not characterize this year as limited to third party due diligence. I am not sure why Ms. Chen focused on third party due diligence but frankly there have been a number of significant developments in compliance, including...