Tagged: Ethics and Compliance

Should the Definition of “Foreign Official” Matter?

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us with this posting.  Lauren can be reached at lconnell@volkovlaw.com.  Her profile is here. FCPA practitioners are familiar with the term “public international organization” as included in the definition of “foreign official” for FCPA liability purposes but do we really know what the term means? Recent activity in an enforcement action for allegedly bribing a...

Compliance 2.0 and Trends: Culture and Technology

Compliance has to continuously improve – as companies innovate, so do critical foundation functions like compliance. The forces of change on corporate governance and compliance were unleashed years ago. There is no way to put the genie back in the bottle – the wave is continuing to grow and so long as corporate misconduct continues, corporate compliance will continue to reinvent itself in new ways....

Turning the CEO Around: How to Make Sure the CEO Embraces Ethics and Compliance

Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement. Yet it is common to see a CEO who is not committed and a Chief Compliance Officer who is in denial and points to half-hearted steps to justify their own self-deception. CCOs need to take...

Defining a Corporate Culture of Ethics and Compliance

Some things are easy to define by negative inferences. Corporate ethics or business ethics are not the same as legal ethics. Business ethics are not the same as our philosophy ethics – Aristotle and all of the classic philosophers were not operating in a corporate context. Some things require a positive definition. To bring about real change in the area of business ethics, a clear...

Culture Caution: Should You Accept a New Job as a CCO at a Company?

Before a Chief Compliance Officer accepts a new position with a company, a potential CCO should conduct his/her own “due diligence” of the prospective employer. A company without a corporate culture of ethics and compliance can pose serious challenges for CCOs seeking to implement an effective ethics and compliance program. In the absence of a real commitment from the board and the CEO, a CCO...

Webinar: Compliance 2.0 — A New Model for Ethics and Compliance Programs

Webinar: Compliance 2.0 — A New Model for Ethics and Compliance Programs Tuesday, November 10, 2015, 12 Noon EST Register Here In the last year, ethics and compliance leaders have been describing a new model for ethics and compliance programs, referring to it as “Compliance 2.0.” For compliance professionals, Compliance 2.0 includes a number of important principles relating to the role of the Chief Compliance...

Business Ethics as an Effective Control

Integrity has no need of rules. – Albert Camus Corporate decision-making ignores important principles and sometimes, common sense. With the increase in corporate compliance programs, corporate boards and senior executives need to take a moment to address one important issue – the importance of creating an ethical culture. For some reason, corporate boards and leaders like to focus on the tangible aspects of ethics and...

The 5 Key Ingredients to a Culture of Ethics

Every company wants to create a culture of ethics. If the senior leadership ignores or downplays a culture of ethics, they have narrowed business opportunities for the company, its shareholders, and other stakeholders. A culture of ethics does not guarantee financial success, but it does add to the bottom line financial performance of a company. There are a number of necessary ingredients that have to...

Ethical Business Decision-Making

An effective ethics and compliance program, by definition, translates into ethical business decisions. Believe it or not, to bring ethics into the equation you do not need to be a philosopher, historian, or professional ethicist. Ethical decision-making is a discipline. It is an approach to identifying and resolving issues in the business context. Of course, it occurs in many other contexts. Nor can ethical business...

The True Impact of DOJ’s Individual Prosecution Memo

The Justice Department can surprise you – the release of the Yates Memo (here), as it is commonly referred to since it takes on the name of the Deputy Attorney General (e.g. McNulty Memo), is another strange example of DOJ responding to political winds. If anything, DOJ’s action appears a little bit late. The controversy surrounding DOJ’s failure to prosecute an appropriate number of individual...