Tagged: ethical culture

Episode 261 — 2023 Ethics Compliance Predictions and Trends

I always enjoy pulling out the crystal ball and looking forward with due consideration of last year’s trends.  It is a perspective that gives us all the opportunity  to identify important trends and to set an agenda for the next year – 2023. The compliance profession continues to grow in overall importance in the corporate governance landscape. Corporate leaders that fail to appreciate this face...

LRN and Tapestry Networks Issue Important Guidance for Corporate Boards and CEOs to Build and Manage Ethical Cultures

You can always count on LRN.  No ifs, ands or buts, LRN continues to issue the highest-quality and most meaningful research and guidance on ethics and compliance programs.  LRN digs in to ask the hard questions, measures important trends and consistently provides importance support and guidance for corporate governance.  LRN is a must read in these areas. Now that I finished by promotional rant, let’s...

Wells Fargo’s Woes Continue — A Rotten Culture that Continues to Stink

It is hard to write yet another posting about Wells Fargo’s misconduct.  Wells Fargo’s troubles continue unabated.  I am not exaggerating — I promise.  Every few months, we hear about another problem, another enforcement action, another uncovering of misconduct.  I do not intend to attempt to even recount all of Wells Fargo’s horrible history.  We all know it, and like a rotten fish, we all...

Episode 240 — The CCO’s Role in an Effective Compliance Program

I have been — and continue to be– hyper-focused on the proper role and responsibilities for Chief Compliance Officers. Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called hot issues — ESG, Diversity, Climate Change, Threats to Democracy, Cybersecurity and Data Privacy, each of which is an important component and focus for organizations. All of these...

Where Does Your Compliance Program and CCO Fall Under DOJ’s Independence, Authority and Resources Test? (Part IV of IV)

As we enjoy the remainder of the summer and get ready to launch into a new fall season (no, not football) but a time for renewal and recommitment, this may be a good opportunity to examine and analyze your own compliance program.  DOJ’s framework provides a valuable set of questions and issues needed to conduct this analysis.  It is important to note the critical ability...

The Effective CCO: Independence, Authority and Resources (Part III of IV)

As Supreme Court Justice Potter Stewart eloquently opined in Jacobellis v. Ohio (1964), on the legal definition of obscenity, “I know it when I see it.”  This same test applies to other issues as well — when it comes to an effective ethics and compliance program, and an effective CCO, “[We] know it when [we] see it.”  Or conversely (and perhaps confusingly), “[We] know it...

The Importance of Ethics and Compliance to the Overall Corporate Mission (Part II of IV)

There are lots of sources for compliance guidance — prosecutors, regulators, compliance organizations, and many others have set forth important and valuable guidance for the design and implementation of an effective ethics and compliance program.  All of this guidance is helpful and has advanced the cause of corporate compliance.  After all, for decades now, the importance of corporate ethics and compliance has steadily grown.  It...

The Chief Compliance Officer: The Blueprint for Success in the Future (Part I of IV)

OK, I admit it.  I have been — and continue to be– hyper-focused on the proper role and responsibilities for Chief Compliance Officers.  Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called hot issues — ESG, Diversity, Climate Change, Threats to Democracy, Cybersecurity and Data Privacy, each of which is an important component and...

Episode 235 — Third-Party Risk Management

The global economy has suffered two significant shocks — first, the pandemic sent shockwaves through every organization, and second, the war in Ukraine. Both of these events exposed the importance of risk management, especially with regard to supply chain and distribution operations. Hence, the renewed focus on third-party risk management and the repetitive description of “holistic” third-party risk management.  Reality has a way of forcing change and...

The Upside of Managing Third-Party Risks: Advancing Your Culture (Part III of V)

While I have devoted the first two postings to outlining all the downside risks of third-party management and threats to overall organization resiliency and operations, it is important to consider the positive upside of managing your third party population.  After all, a large number of third parties represent your organization, such as agents, distributors, and resellers, in the marketplace and frequently interact with company customers. ...