Warren Buffet, the Oracle of Omaha, understands the importance of corporate culture and adhering to a code of ethics. He has been quoted: Lose money and I will forgive you. Lose even a shred of reputation and I will be ruthless. …… Wealth can always be recreated, but reputation takes a lifetime to build and often only a moment to destroy. Buffet’s implicit message is unmistakable – culture, reputation and...
Webinar: CCOs and the Board of Directors: Establishing an Effective Relationship May 24, 2016 12 PM EST Register Here Chief Compliance Officers have to establish a positive and productive working relationship with the corporate board of directors. An effective reporting relationship is essential to ensuring an effective ethics and compliance program. CCOs have to attend to this relationship, learn how to use it effectively, and...
Chief compliance officers continue to enjoy these heady days – salaries are up and new opportunities are popping up in the corporate world. CCOs have to keep their eye on the ball. It is well and good to get a good salary, a nice office, and a title, but there is an important requirement that cannot be overlooked – independence. The trend over the last...
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...
A speak up culture is an important component of a company’s commitment to organizational justice. All of the pieces of an internal justice system have to fit together and are interdependent. When one part does not work, the whole system does not work. A robust internal investigation system is a critical component of organizational justice. Companies often pull together the basic components of an internal...
Happiness is when what you think, what you say, and what you do are in harmony – Mahatma Gandhi Happiness is an elusive concept – for some. For others who may be more enlightened or lived for years, happiness is a feeling that can be attained by commitment, determination and awareness. My keys to happiness are love, gratitude and empathy. Some people are “content” being...
One of the more frustrating topics for discussion is defining business ethics. It is frustrating to see how complex and unhelpful the discussion turns when defining business ethics. I have two tests for how to deal with this issue. Do you use simple terms that can be easily communicated internally in a company? Do the terms embrace the kind of values important to the company?...
Just when you thought things could not get any weirder, along comes the New York Department of Financial Services and proposes a new regulation that sets forth minimum requirements for anti-money laundering transaction monitoring systems and sanctions watch list filtering. The regulations include an annual requirement that the Chief Compliance Officer at New York banks and money transmitters certifies that the bank’s or money transmitter’s...
DOJ’s compliance counsel, Hui Chen, pronounced this year as the compliance year of third party due diligence. This has been a good year for compliance, but I would not characterize this year as limited to third party due diligence. I am not sure why Ms. Chen focused on third party due diligence but frankly there have been a number of significant developments in compliance, including...
Individual commitment to a group effort – that is what makes a team work, a company work, a society work, a civilization work.~ Vince Lombardi Like so many areas in life, a successful ethics and compliance program depends on teamwork. My last two postings, Parts 4 and 5, will highlight these essential partners – senior leadership and key compliance functions. In a company culture, teamwork...
