Having a robust triage system is an important way that a company can separate the wheat from the chaff and bring the right number of resources to bear on a problem.
Manti Te’o and a Second Set of Eyes
February 19, 2013
The Manti Te’o story provides some significant lessons for the compliance practitioner. Putting a ‘second set of eyes’ on any process, including compliance is the only way to validate the process.
The Bribery Act in 2012: a Year for Transition
February 8, 2013
The past year has been one of transition for the UK Bribery Act and the Serious Fraud Office…
How Do You Move Ethical Values Down Through Your Company?
February 4, 2013
What do employees want most in their company’s values? . I would argue that one of the concepts which should be in the conversation is respect for a company’s ethical values.
The Lance Armstrong Confession: Lessons in Ethics and Compliance
January 22, 2013
I want to focus on three points which the compliance practitioner can glean from Armstrong’s career and interview and how that information can be used to create a more robust ethics and anti-corruption compliance program…
The CCO: Co-Equal to the General Counsel in the Eyes of the DOJ
December 20, 2012
I think that the DOJ and SEC are moving companies to not only have more robust compliance programs but the CCOs and their programs must be adequately situated within the organization and adequately funded…
The FCPA Guidance and Declinations
December 11, 2012
The release of substantive information on declinations would help foster greater compliance with the FCPA by providing practitioners with specific facts of circumstances where investigations did not result in an enforcement action…
Five Essentials of a Chief Compliance Officer Position
December 6, 2012
While all CCO positions should be “fit-for-purpose,” there are five essential features which are consistent to all such positions…
Embracing Chaos To Build Compliance Programs
December 3, 2012
The hierarchical model of leadership will not work, but more importantly, there exists no single model that leads to success. This means that compliance leadership must be ready to throw aside previous assumptions and embrace hierarchical top-down leadership and bottom-up systems.
More and More Questions for Wal-Mart
November 29, 2012
Fox’s favorite Sherlock Holmes novel, “The Hound of the Baskervilles,” comes to mind when he ponders serious and difficult questions for Wal-Mart, its Indian subsidiary, and others.
