Chief compliance officers face a mountain of tasks – it is easy to get overwhelmed.  Add to the mix the fact that CCOs are under extraordinary pressure to “prevent and detect” potential violations of the company’s code and any law or regulation.  When you think about it, that is quite a heavy responsibility. In the ebb and flow of ethics and compliance ideas, one constant...

Companies face a myriad of risks that can cause significant legal and reputational risks.  A company’s employees are critical sources of concerns to prevent and detect problems.  Employees have to be encouraged to raise concerns to help the company address these problems proactively.  As a result, it is critical for companies to invest and promote its speak up culture to maximize employee communication and prevent...

Corporate commitment to speak up cultures is suffering.  The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey (available HERE) contained a critical finding – corporate instances of retaliation against employee for raising concerns doubled in the last five years. In the 2013 survey, 22 percent of respondents reported instances of retaliation against employees.  This number increased to an astounding 44 percent of respondents...

As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives.  So, our kids start to speak up and we listen, patiently, but at some point, our patience wears thin, and we are not as interested or willing to listen.  Our children begin to question our...

Webinar: How to Implement an Effective Internal Investigation Program Tuesday, February 6, 2018, 12 noon EST SIGN UP HERE An effective ethics and compliance program depends on an efficient internal investigation function. Corporations have to design and implement an internal investigation system that is fair, timely and reliable. To do so, companies need to identify risks, assign resources, monitor investigations and mete out disciplinary actions....

Sign Up for Three-Part Webinar Series:   Internal Investigations Systems (Part I):  November 29, 2016, 12 PM EST Sign Up Here   Interviews and Internal Investigations (Part II): December 6, 2016, 12 PM EST Sign Up Here   Speak Up Culture (Part III) December 13, 2013, 12 PM EST Sign Up Here Companies are struggling to establish and embed a Speak Up culture.  Companies need...

Every company has put in place a reporting hotline – whether a telephone number and/or website, companies offer employees an avenue to raise a concern. Employees will report concerns, but they have to trust the reporting system to be responsive. When you ask compliance professionals and others who monitor the reporting system if it is valuable, you hear the common statistic – 80 percent of...

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...

If your company is big enough and has the resources to consider establishing an internal ombudsman’s function, consider yourself lucky. When compliance professionals and lawyers use the term “ombudsman,” it is important to define how the term is being used. The most effective model for an ombudsman is the creation of an entire independent investigation and resolution function within a company. In this model, the...