Ethics and compliance has to stand strong when new trends suddenly spring up. Organizations are always ready to embrace the new-fangled shiny object – in this case ESG. Not to be a nattering nabob of negativism (see Spiro Agnew’s comment in 1966 crafted by William Safire), but organizations have to take a deep breath and renew a review of its ethics and compliance program fundamentals. ...
Webinar: Speak Up – How to Foster a Culture of Compliance September 17, 2020, 12 PM EST Sign Up Here. A Speak Up culture empowers everyone in the organization to be the “eyes and ears” of compliance, communicating important information on potential problems before they spiral out of control. This type of culture is an integral part of a best-in-class compliance program, however creating it...
Many global companies are behind the eight-ball (translation, slow to implement) effective antitrust compliance programs. A small number of companies, some of which have suffered antitrust enforcement actions or operate in high-risk industries, have implemented innovative antitrust compliance programs. These programs stand out in the compliance landscape. An effective antitrust compliance program typically includes robust training programs, well beyond dry in-person or webinar-based recitations of...
Webinar: Maintaining a Reliable and Effective Internal Investigation 12 Noon EST,March 24, 2020 Sign Up HERE A company’s commitment to implementing an effective ethics and compliance program must include a reliable internal investigation program. In order to build trust and a speak up culture, an internal investigation program has to respond promptly and fairly to employee concerns. Companies that operate a bare bones or ineffective...
2019 was a big year for ethics and compliance. In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year. The federal government issued three important documents in 2019 – DOJ issued the Evaluation of Corporate Compliance Programs from the Criminal Division (here) and from the Antitrust Division (here),...
Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising concerns. It all sounds great and is usually reflected on paper in the form of positive statements in the code of conduct and other communications. All too often, however,...
The twist and turns of our political world amid the ongoing controversy surrounding whistleblower reporting has focused attention on an important issue – encouraging whistleblowers as part of a speak up culture and protecting them from retaliation is critical. Without getting into the merits of the specific allegations raised by the CIA whistleblower, the political debate concerning the identity, motives and protection of the whistleblower...
In the compliance idea marketplace, there has been an increased focus on the importance of maintaining an organization’s speak up culture and the importance of a reliable and efficient internal investigation program. From a practical standpoint, if a company has a defective program for encouraging reporting, and conducting timely and efficient investigations, the company is likely to suffer from some serious breakdowns in conduct and...
Companies are starting to understand that an effective internal investigation program is a critical function to promote a speak up culture. A company that has a dysfunctional internal investigation program will find it difficult to prevent and detect misconduct. To this end, companies have to commit to a multi-step review and improvement process for its internal investigation program. This is an exercise that is limited...
Corporations have to invest in their Speak Up Culture. A critical component is a company’s hotline and incident reporting system. An effective hotline reporting channel(s) depends on responsive and timely investigations of potential wrongdoing. In this Episode, Michael Volkov discusses best practices for hotline and reporting systems.
