5 steps to walk you through an investigation in a clear, concise and cost effective matter.
Companies respond differently to compliance challenges, particularly in the way in which they encourage and embrace whistle-blowers.
One of the areas where the best practices for Foreign Corrupt Practices Act (FCPA) compliance programs is evolving is in the area of a less U.S.-centric approach and incorporating the diversity across the globe. Many companies are now realizing that there should not be a one-size-fits-all compliance program and that there is a treasure trove of ideas and capabilities in the compliance arena around the globe.
Just as you can learn and experience history by studying the individuals who participated in great events, your compliance program should be aimed at individuals to guide their ethical behavior based upon your company’s compliance regime. You should think of Sir John Keegan’s work on the individual in battle in conjunction with what your compliance program is doing to prevent and detect fraud of individuals in your company.
Thomas Fox reviews the Enhanced Compliance Obligations, Attachment C.2, and Corporate Reporting Obligation, Attachment C.3, which Pfizer agreed to implement and operate under.
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 [...]
Ryan Braun’s steroid suspension was overturned because his urine sample was not handled in compliance with MLB’s testing protocol. As important as it is to have a written process in place, it is just as important to follow the process. Thomas Fox discusses why this matters and how you can build employee trust in your compliance program.
I was watching the Grammy Awards show last night and found my love for Adele Adkins thoroughly validated. She is phat. Not “f-a-t” of course but “p-h-a-t” – i.e., urban slang for very attractive or appealing. I know, I know. It’s a really bad play-on-words in light of the unfair controversy over her appearance. I [...]
Last summer, the University of Pennsylvania’s Journal of Business Law published an article titled “The OECD’s Call for an End to the ‘Corrosive’ Facilitation Payments and the International Focus on the Facilitation Payments Exception under the Foreign Corrupt Practices Act.” It was authored by Jon Jordan, senior investigations counsel, in the Foreign Corrupt Practices Act (FCPA) Unit of [...]
As the transition from December to January is a time for reflection about the past 12 months, I have been considering the FCPA enforcement action of the year. I submit for your consideration my Top 10 FCPA Enforcement Actions for 2011 in the corporate division. Happy New Year to all.