I have a pet peeve in the compliance world. It may be symbolic; it may be petty at the same time; and it may just be a function of my old(er) age. I apologize in advance for this posting, i.e. this rant. Call it my moment on the front lawn yelling at passing cars in the neighborhood. My moment of frustration. Let’s start with two...
Jessica Sanderson, Of Counsel, The Volkov Law Group, rejoins us for a posting on the importance of compliance during the COVID-19 pandemic. Jessica can be reached at [email protected]. In these challenging times, when governments around the world are asking all “non-essential” workers to stay home, and companies are struggling with business interruptions and difficult decisions regarding pay-cuts, layoffs and furloughs, we’ve been thinking a lot...
This week I am examining in a four-part series the issue of business ethics in an attempt to provide practical approaches to business ethics to help build and promote a company’s culture. As more attention is paid to the importance of an ethical culture, I wanted to first offer some general observations. The field of business ethics is thick with definitions, moral arguments and theoretical...
A corporate entity is like its own community – it has a culture, a set of values and principles that form the foundation for the company’s operations, and an overall purpose. The interesting factor that has to be identified, assessed and addressed is that a corporate entity has to be profitable, or in other words, it has to make money. We often hear that a...
Compliance practitioners divide their commentary and insights into two general categories – ethical culture and compliance controls. It is easy to divide compliance issues into these two categories. Ethical culture articles are a little less concrete; compliance controls are practical and focused on policies and procedures. A compliance program cannot be deemed effective, however, unless there is a combination of these two important functions. An...
When looking through the wreckage of a major corporate compliance disaster, it is relatively easy to spot the important events when business needs (or money) are consciously elevated over compliance concerns or even reputational risks. It is easy to spot the circumstance, and with perfect hindsight announce to everyone (assuming someone is listening) that you would not have followed that course of action. In the...
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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?...
Each year I have identified the so-called “person” of the year to capture the most significant enforcement and compliance trend. In the past, I have given the award to the Chief Compliance Officer, the Ethics Officer, the Prosecutors, and others. This year is not an easy choice. In my view, there have been three significant events or trends, each of which could easily be named...
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about third-party due diligence. Lauren’s profile is here, and she can be reached at [email protected]. Most discussions of third party due diligence begin with an explanation of indirect liability and the “deliberate ignorance” standard of knowledge the FCPA imposes. With so much focus on anti-bribery it is easy to lose...
