Tagged: culture of compliance

Organizational Justice: The Importance of Transparency

You know a company’s culture is suffering when you hear the CEO or senior executives say the best way to develop a “Speak Up” culture is to just tell all the employees “we want to hear from you.” I am an advocate for simplicity but sometimes simplicity can slip into stupidity. A “Speak Up” culture requires a commitment to a number of important principles and...

Applying Practical Strategies to Supply Chain Risk

A Chief Compliance Officer can get so overwhelmed with risks that it is hard to keep their focus on priorities. Risks are everywhere and no compliance program can address every risk – the trick is keeping your eye on the ball and focusing on the significant risk. There are lots of risks surrounding a company’s supply chain. Unfortunately, vendors, suppliers and their respective vendors and...

DOJ’s Compliance Counsel & Compliance Expectations

The Justice Department’s hiring of Hui Chen as the new Compliance Counsel is an important development in DOJ’s prosecution of corporate defendants. It is not clear yet what impact Ms. Chen will have. At a recent event at NYU (video here), Andrew Weissmann, the head of the Fraud Section, and Ms. Chen spoke about the new compliance position. The video provides important information. Ms. Chen...

Defining Compliance 2.0: The CCO (Part 3 of 5)

These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure. We now have debates over the independence of the CCO from the legal function, the reporting obligations and the relationship between the CCO and the board. There is no question that CCOs have...

Turning the CEO Around: How to Make Sure the CEO Embraces Ethics and Compliance

Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement. Yet it is common to see a CEO who is not committed and a Chief Compliance Officer who is in denial and points to half-hearted steps to justify their own self-deception. CCOs need to take...

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...

New “Guidance” from DOJ on Compliance

I am a positive person (anyone who has to say that raises doubts). At least I like to think I am. I am not yet sold on the wisdom of DOJ’s hiring of a compliance counsel. Frankly, I have a lot more respect for the knowledge and experience of line prosecutors at DOJ and their supervisors on this issue – they know and understand compliance...

Culture Caution: Should You Accept a New Job as a CCO at a Company?

Before a Chief Compliance Officer accepts a new position with a company, a potential CCO should conduct his/her own “due diligence” of the prospective employer. A company without a corporate culture of ethics and compliance can pose serious challenges for CCOs seeking to implement an effective ethics and compliance program. In the absence of a real commitment from the board and the CEO, a CCO...

Business Ethics as an Effective Control

Integrity has no need of rules. – Albert Camus Corporate decision-making ignores important principles and sometimes, common sense. With the increase in corporate compliance programs, corporate boards and senior executives need to take a moment to address one important issue – the importance of creating an ethical culture. For some reason, corporate boards and leaders like to focus on the tangible aspects of ethics and...

The 5 Key Ingredients to a Culture of Ethics

Every company wants to create a culture of ethics. If the senior leadership ignores or downplays a culture of ethics, they have narrowed business opportunities for the company, its shareholders, and other stakeholders. A culture of ethics does not guarantee financial success, but it does add to the bottom line financial performance of a company. There are a number of necessary ingredients that have to...