Ethics and compliance has to stand strong when new trends suddenly spring up. Organizations are always ready to embrace the new-fangled shiny object – in this case ESG.  Not to be a nattering nabob of negativism (see Spiro Agnew’s comment in 1966 crafted by William Safire), but organizations have to take a deep breath and renew a review of its ethics and compliance program fundamentals. ...

The FCPA Guidance issued by the Justice Department and the SEC says it best – “The truest measure of an effective compliance program is how it responds to misconduct.”  These are prophetic words.  Many organizations, however, cannot pass this basic test.  Indeed, if we look at the Ethics and Compliance Initiative’s 2021 Global Business Ethics Survey (GBES), the conclusion is inescapable: organizations’ ethical cultures are...