It is important to understand one’s limitations in life. In the world of compliance, this means CCOs need to be realistic when they start a new job with a new company. It also means that a CCO has to be honest with himself or herself. Deep down, every person knows their strengths and weaknesses.
The buck stops at the CEO. Well, yes and no. The CEO needs to create a leadership team setting where core strategic foundational data is established and implement a system that cascades throughout the company to link …
What does Woodstock have to do with compliance? Tom Fox tackles the question in a discussion regarding the importance of a company’s culture.
Corporate cultures need to progress from motivation by individual self-interest to inspiration for the greater good, from checks and balances to trust, and from rules-based behavior to being guided by what is right—just like strong safety cultures have already done.
Section 922 of the Dodd-Frank Act, which establishes SEC whistleblower mechanisms, is now in full effect. As if FCPA risks were not already high enough, now companies have to consider whistleblowers. How to manage this threat? By encouraging employees to report FCPA violations internally first, through pre-existing compliance programs.
Most compliance programs have less than five hours of employees’ time each year for dedicated compliance and ethics training (or barely a minute per day!). So, how do we shape employee behavior while allowing for the strategic freedom, entrepreneurial spirit, and on-the-job innovation that drive corporate success?
Thomas Fox takes a look at the journey of Cathy Choi, president of an energy-efficient light bulb manufacturer, as she found a way to instill values in her company as she took the reigns. Her approach could be used in the context of implementing a compliance program.
The financial crisis imposed immense costs on the nation and our financial system. And it didn’t need to happen. Good management and governance could have saved our largest institutions. As a senior staff member of the Financial Crisis Inquiry Commission (FCIC), I interviewed CEOs, traders, risk officers, board members, and regulators to try to understand: What did successful firms do that kept them out of trouble?
Management that turns deaf ears when subordinates report false billing or illegal marketing in dealing with federal or state governments can unleash a torrent of financial and reputational harm on the company. Indeed, that scenario is just the sort of situation that can turn into a full-blown, multi-million-dollar whistleblower settlement brought by a company insider under qui tam provisions of federal and state False Claims Acts.
The Freeh Report was released last week. It detailed a series of actions and inactions taken by officials at Penn State University (Penn State) that allowed Jerry Sandusky to continue his abuse of young boys from at least 1998 up until the time he was arrested.
As bad a situation as the Freeh Report portrays, I believe that there are significant lessons for the Foreign Corrupt Practices Act (FCPA) compliance practitioner and I will try to draw out some of these lessons learned.