The Justice Department’s recent Yates memorandum on individual accountability is a significant event. Sure, you can always find members of the FCPA Paparazzi who will discount the memo, or relegate it to a mere “political” statement. That view is unfortunate and ignores the real implications of the Yates memo. Such a viewpoint also shows how little members of the FCPA Paparazzi understand the true inner...
Ethical companies, by definition, have a robust system for internal organizational justice. A company that suffers from unequal treatment of similarly situated executives, managers, and employees cannot maintain an ethical culture. Unequal justice will undermine employee morale, reporting of misconduct, and overall productivity rapidly. Cynicism breeds contempt, and there is nothing like employee discontent when it comes to the sustainability of corporate productivity. To ensure...
Webinar: Update to Internal Investigations Best Practices October 13, 2015, 12 Noon EST Sign Up HERE The Justice Department’s recent announcement of a new policy governing individual accountability in corporate internal investigations will have a significant impact in the conduct of internal investigations. Companies will have to provide complete information about all individuals involved in potential misconduct in order to earn any cooperation credit. DOJ’s...
