Tagged: Culture

Who is Responsible for a Company’s Mood in the Middle? – the Wells Fargo Fiasco

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on the Wells Fargo scandal.  Lauren can be reached at lconnell@volkovlaw.com. Wells Fargo’s cultural tone is not easily segregated between “top,” “middle” and “bottom.”  Despite the recent cross-selling scandal, in which the CFPB led an enforcement action whose fines total a whopping $185 million, Wells Fargo’s CEO John Stumpf reluctantly...

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...

Incident Management – The New Frontier

Compliance programs are required to create and manage case investigation systems to handle potential misconduct, investigate allegations of wrongdoing and then dispense discipline. Lessons learned from these investigations are valuable sources of information to improve compliance programs. Chief compliance officers play a critical role – either supervising the internal investigation system or coordinating with other functions in the organization to monitor internal investigations. Along the...

Creating an Ethical Culture and “Outside” Influences

Forgive me for taking a step back to address an important challenge in creating a culture of compliance. I know this may sound obvious but in today’s “toxic” political environment it is important to point out some factors that may be beyond the influence of a corporate culture, its leadership and its compliance team. I have consistently ignored commenting on political issues and will continue...

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...

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...

The Two Essential Requirements for Tone-At-The-Top

Everyone likes to give advice on the importance of tone-at-the-top. Like many things in life, it is easy to talk about but much more difficult to implement. There are lots of ways to describe or analyze the same issue. In the end the result has to be reached. To boil it down, tone-at-the-top requires leadership. That is pretty obvious. But, what kind of leadership? This...

The Necessary Ingredient to Compliance Success: Interpersonal Skills

We always bandy the phrase around of “people skills,” or the old trendy phrase of “emotional intelligence.” Hopefully, this posting can create some ideas around new approaches to these old concepts and trendy terminology. Compliance professionals need to develop strong interpersonal skills. It is one of several important personal skills and talents that are needed for a compliance officer to succeed. Maybe the point is...

Promoting Your Culture: Communications and Measurement

As everyone knows, I am an advocate for promoting and maintaining a company’s culture of ethics and compliance (not compliance and ethics). The best investment a company can make is to create and maintain a positive commitment to an ethical culture. I often repeat myself (just ask my wife and kids), but a culture of ethics is far more important than well-designed and effective policies...

The Time is Now to Amend the US Sentencing Guidelines on Corporate Ethics and Compliance Programs

We all know the importance of the sentencing guidelines and the impact the revisions, especially the 2010 amendments, have had on corporate governance and compliance. The history behind the sentencing guidelines tracks the rise of the compliance profession. The time is now for the Sentencing Commission to launch a further review of the guidelines to reflect the rapid changes in the compliance profession. The Sentencing...