What Steps Can Lead to a Reduction in a FCPA Fine?
Thomas Fox reviews the steps taken by Alliance One and Universal Corporation during the pendency of their respective FCPA investigations to reduce their fines for FCPA violations.
Thomas Fox reviews the steps taken by Alliance One and Universal Corporation during the pendency of their respective FCPA investigations to reduce their fines for FCPA violations.
If the first part of this post sounds famailiar, you may be experiencing an overload of “corporate speak” and it may be time to take another look at your internal communications.
By Steve Liccione — Director of Corporate Compliance for Johnson Controls
When an organization sets the proper “Tone at the Top,” it is often laudatory and occasionally inspiring. But, it does not necessarily prevent corporate misconduct. It may not even dissuade it. C-Suite occupants must resist the siren song of “Tone” that can lull them into a sense of complacency. The “Top” can be duped into believing that it has done its part by merely singing the appropriate compliance lyrics.
As with people, a company’s actions – rather than words – best reflect intent and commitment. An executive’s pledge to foster a “culture of compliance” is insufficient. There must be an enterprise-wide dedication of resources to the compliance function. This commitment need not be measured solely in hard dollars or dedicated compliance staffing. Rather, properly directed employee efforts may be more significant and yield better results than hiring troupes of lawyers and accountants.
A strong code of conduct offers real value to a company. With a little foresight and focus, a company can develop a new code or enhance an existing code to reap the numerous benefits it can provide.
Nancy Singer describes a seven-step program to help companies avoid damage from carelessly written documents.
In this CCI featured article, Tim Lupfer and Mike Fuchs of Deloitte Consulting share their advice on how to effectively managing human capital risk, including best practices for risk management training and ingraining risk management into the corporate culture.
Theresa Mack, Senior Manager at CCA Advisors, discusses how newly proposed SEC regulations, as well as the struggling economy, are highlighting the need for increasing disclosure as well as thorough background investigations of applicants and on-board employees.
In the latest CCI featured article, Sharie Brown, chair of FCPA and Corporate Compliance at DLA Piper, provides a list of “red flags” companies can instruct their employees to watch out for to manage compliance risk of overseas operations. Red flags are included for the areas of anti-bribery, export controls, anti-money laundering, anti-terrorism, and anti-boycott risks.
By Karina B. Sterman, Esq., Partner in the Litigation and Employment Law Departments of Ervin Cohen & Jessup LLP.
Entrepreneurs, statisticians, and business analysts all recognize that, when harnessed and managed properly, cultural diversity in the workplace contributes to great creativity, productivity, and ultimately to the growth and prosperity of a company.
However, there is a tremendous divide between the theoretical belief in cultural diversity and the practical implementation of training and fostering a culturally diverse yet cohesive workforce. Training employees with different cultural attitudes is a challenging opportunity to be approached with sensitivity, open mindedness, and awareness.
Most modern workplaces today are melting pots of diverse social, economic, ethnic, religious, and other cultural backgrounds. An employee’s cultural background largely frames that employee’s perspective on authority, on gender roles, on hierarchy, on responsibility, on assertiveness, and other traits that deeply and fundamentally determine the success of a corporate culture.
So, the critical inquiry for every workplace must be, “Are cultural wars killing your corporate culture or is your corporate culture creating culture wars?”
By Ron Kral, Managing Director of Candela Solutions
Many organizations will be facing financial reporting control assessments and related external audit pressures for the very first time over the next two years. Yes, public companies have suffered millions of dollars in costs with limited benefits. Yes, there are regulatory inefficiencies and strained auditor relationships. Yes, I am talking about Section 404 of the Sarbanes-Oxley Act of 2002 (SOX). No, it does not have to be a wasteful exercise resulting in minimal benefits. This article identifies newer applicable organizations and the cornerstones to streamlining control assessment leading to cost-efficient and effective results.