Tagged: Culture

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...

A Hands-On CEO and Support for Compliance

A compliance program without CEO support is almost doomed to be ineffective. We all live by the standard of an “effective” ethics and compliance program. I am always reluctant to embrace a dogmatic expression but the support, and hands-on participation of a CEO, can be the difference between an effective and ineffective compliance program. A CEO not only has to embrace the importance of an...

4 Signs of a Weak Culture of Compliance and Ethics

We all know the importance of promoting a culture of compliance and ethics. The benefits of an ethical culture are substantial and worth every penny of investment in creating and promoting such a culture. We do not need to spend time justifying why an ethical culture is important to company financial success – it is critical for corporate sustainability and profitability. Not every company has...

The Microeconomic Perspective on Bribery Incentives

I always enjoyed economics – understanding “rational” behavior and applying it to business situations can be very productive. Of course, there were many detractors who argued that economics is filled with assumptions that take the discipline away from reality, but I find those arguments unpersuasive. There has been a fair amount of research on corruption and the impact that bribery has on a functioning market....

Warning: Keeping Compliance Simple

If you can’t explain it to a six-year-old, you don’t understand it yourself. — Albert Einstein Compliance professionals are in a heady state these days. Their stock is rising; they are gaining influence and authority, and even some additional resources. When given the time, compliance professionals can come up with new and innovative strategies for compliance programs. But I see a danger lurking in the...

Encouraging Employees to Break the “Rules” to Do the Right Thing

Lauren Connell of The Volkov Law Group joins us again for a posting about corruption and gifts and hospitality.  Her profile is here and she can be reached at [email protected] Laws and regulations draw black lines in often-gray areas. That is their purpose; they exist to make it easier to tell what is “wrong” and what is “right” (as defined by whoever made the law)....

Parallel Prosecutions and U.S. Jurisdiction: Looking Beyond the Bribes in the FIFA Scandal

Lauren Connell from The Volkov Law Group joins us again for a posting about the implications of the FIFA Scandal.  Her profile is here and she can be reached at [email protected] Everyone is talking about the latest corruption scandal, this one with world-wide impact. The scandal engulfed FIFA as seven organization officials were recently arrested in Switzerland. Charges include a range of money laundering, racketeering,...

Wall Street and Ethics

I have to confess that there is a part of me that was skeptical about a new survey released last week finding that banks and other financial institutions have not embraced a culture of integrity.  (Survey Here).   Indeed, the survey found that numerous individuals continue to operate with the idea that illegal or unethical behavior is a necessary part of succeeding in the financial markets....

The New Role of the CCO: Good News and Bad News

There is no question that the compliance profession is on the rise. My colleague, Donna Boehme and I, frequently advocate on behalf of the compliance profession. See here for our latest – 4 Steps Every Board of Directors Should Take Toward Compliance. With the rise of the CCO in corporate governance circles, there are adjustments that have to be made in other areas. What do...