The answer is debatable, but Frank Bucaro argues if the training incorporates the essential elements, results will be obvious and felt throughout the entire organization.
Tone at the Top: Ethical Dilemmas
What rationalization does a company make to justify a corporate culture where ethics are ignored? In recent years, greed, fraud, and a lack of ethical conduct have led to the collapse of many organizations. A variety of internal and external pressures can lead companies down the wrong path. And once the first misstep is taken, [...]
Turning Compliance Beliefs Into Action: Impacting Tone at the Bottom
Tone at the top has become almost a by-word in the corporate compliance world these days. It is specifically mentioned in the U.S. Department of Justice’s (DOJ) 13-point minimum best practices compliance program as well as the U.K. Ministry of Justice’s (MOJ) Six Principles of Adequate Procedures. How does a compliance practitioner tap into ethical beliefs of a [...]
Does Wal-Mart Have a Facilitation Payment Exception to the FCPA?
In this article Thomas Fox visits the text of the FCPA and other Department of Justice (DOJ) commentary, some enforcement actions, one open investigation involving alleged facilitation payments and offer some guidance to the compliance practitioner on what may or may not constitute a facilitation payment under the FCPA.
Incorporating the Fraud Triangle into Compliance Risk Assessments: The “Motivation” Factor
In Part 1 of this series, John Hanson provided an overview of the Fraud Triangle and how incorporating it into compliance risk assessments can improve a compliance program’s assessment and prioritization of compliance risks. Parts 2 and 3 went into more detail concerning the “opportunity” and “rationalization” factors of the Fraud Triangle. Today he focuses on the “motivation” factor of the Fraud Triangle.
Reputation: Is the One You Have the One You Want?
One of my favorite books is Values, Prosperity, and the Talmud – Business Lessons from the Ancient Rabbis by Larry Kahaner. In a concluding section of the book, it states, “[T]he Talmudic rabbis would sum up the secret of business success in one word: Reputation!”
The Righteous Mind: A Must Read for C&E Professionals
Last year saw the publication of an important book on behavioral ethics – Blind Spots – by Max H. Bazerman and Ann E. Tenbrunsel, and in a prior article I describe what some of the implications of this emerging field might be for compliance and ethics programs. In today’s column I want to draw attention to another [...]
Conquering the Fear Factor: A Business Leader’s Responsibility
Bausch and Lomb’s Jim Nortz explores why business leaders must create a culture where employees aren’t afraid to speak up.
Corporate Clergy: Good Knights Sleep Tight
A recent survey by the Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCCA) revealed that many compliance and ethics professionals do not sleep through the night because they are so worried about the issues facing their companies.
I find the study interesting because, in the 23 years that I’ve been a compliance and ethics professional, I can’t ever recall losing sleep over my work.
Ethics Matter
Two recent events spurred Thomas Fox to write about ethics today instead of his usual topic of corporate compliance.
