surveys Archives - Corruption, Crime & Compliance

18 Aug, 2021

Remediating the Organization’s Culture (Part IV of IV)

“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) This straight-forward statement (above) of a company’s commitment to its “effective” compliance program is powerful. In a nutshell, it says it all. Over the years as a federal prosecutor, and later as outside counsel, I have witnessed a variety of responses to misconduct. On the one...

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18 Aug, 2021

Measuring and Reporting on the Organization’s Culture (Part III of IV)

While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures. Let’s start with a simple proposition – if a company’s culture is its most important internal control and its most valuable intangible asset, a chief compliance officer (CCO) should devote commensurate time and energy to promote...