Tagged: ethical culture

A Five Step Program for Every Company to Address the New Enforcement Threats

Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized based on resources.  Instead, these are essential and basic requirements that will inevitably result in significant benefits across the company.  Step 1: Define, Embed and Monitor Corporate Culture...

Corporate Governance Challenges in an Evolving Risk Era

We are living in a rapidly changing economic landscape. Companies are under the gun to navigate “traditional issues,” such as challenging economic conditions ranging from inflation, and a predicted recession, to supply chain disruptions.  It has been a long and difficult path in responding to two significant crises – first the pandemic in 2020 and then Russia’s invasion of Ukraine and the resulting global sanctions...

Episode 273 — British American Tobacco’s $629 Settlement for Evasion of North Korean Sanctions

The Justice Department warned  companies that sanctions enforcement is the “new FCPA.”  Recently, DOJ delivered its first salvo to back up its message. As part of a broad effort to prosecute funding of North Korea’s nuclear program, DOJ and the Office of Foreign Assets Control (“OFAC”) announced a joint settlement with British American Tobacco and its Asian marketing subsidiary (“BAT”), under which BAT agreed to...

Episode 272 — Making Corporate Culture a Reality

Everyone has jumped on the corporate culture bandwagon.  For some new converts, they like to espouse corporate culture as a recent discovery, or a new-fangled approach for compliance programs. The story of corporate culture as a talismanic tool for ethics and compliance is really nothing new.  Chief compliance officers knew the importance of corporate culture from the beginning.  A number of companies separately called out...

Promoting Your Corporate Culture – Accountability and Messaging (Part II of III)

As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture.  In these situations, employee misconduct rates increase, wrongdoing and scandal surround the company, and corporate leaders ultimately fall from failing to sail the corporate ship in the right directions. There are tell-tale signs of...

Making Corporate Culture a Reality: Define and Embed (Part I of III)

Everyone has jumped on the corporate culture bandwagon.  For some new converts, they like to espouse corporate culture as a recent discovery, or a new-fangled approach for compliance programs. The story of corporate culture as a talismanic tool for ethics and compliance is really nothing new.  Chief compliance officers knew the importance of corporate culture from the beginning.  A number of companies separately called out...

Bringing HR and Compliance Together for Compliance and Consequence Management (Part II of II)

The Justice Department’s recent emphasis on ethics and compliance culture, along with greater specificity on “consequence management” is a welcome breath of fresh air.  It is a policy coming for a long time and will bring about significant improvements.  Do not get me wrong – there will be bumps and bruises along the way, hurt egos and turf battles, but in the end HR and...

DOJ’s New Compliance Requirements Mandate Increased Compliance and HR Cooperation (Part I of II)

The Justice Department is now taking on the role of marriage counselor.  Not with individual couples, but with a critical corporate relationship – ethics and compliance and human resources.  Normally, compliance and HR is a match made in heaven.  Unfortunately, in all too many organizations, compliance and HR are having trouble getting along.  This should not be so.  HR and compliance have many joint responsibilities...

Michael Volkov and Susan Divers from LRN Featured on Podcast on How Corporate Boards Are Facing Today’s Global Issues

I was honored to join Susan Divers from LRN to discuss how corporate boards are facing today’s global, regulatory Issues. The Podcast is available HERE. Corporate boards are feeling more pressure than ever from a variety of stakeholders—government prosecutors and regulators, institutional investors, corporate activists, consumers, and others seeking responsible change in an ever-changing global economy. As the concept of both corporate and individual accountability...

LRN 2023 Compliance Program Report Underscores Importance of Compliance Program Vigilance

LRN continues to provide important insights and trends on the importance of ethics and compliance programs.  LRN’s annual report is an important resource and needs to be reviewed by the board, senior management and all compliance-related functions. LRN’s 2023 report emphasizes the importance of commitment, investment and promotion of corporate ethics and compliance, particularly during these difficult economic and geopolitical disturbances. LRN’s report is based...