A CCO's primary focus must be on culture - that is, building a culture of ethics and compliance throughout the organization. Lay this foundation and you'll have gone a long way to minimizing risk. Corporate culture should also make up much of what the CCO reports to the Board and senior management. Michael Volkov has some ...
An E&C program must be effective -- not necessarily convenient. Does the Chief Ethics and Compliance Officer have enough authority and autonomy? What's being reported to the Board, and does the Board have proper oversight of the E&C program? These are just some of the factors that influence the effectiveness of an E&C program.
As popular as the myth of the rogue employee is among companies answering for noncompliance, the reality is that the problem very rarely lies with a lone wolf. Companies make their compliance bed, then they lie in it. Blaming a corporate scandal on a single actor is ignoring the larger problem...
When it comes to compliance, the best investment a company can make is to create and promote an ethical culture. Dollar for dollar, communicating this message is the money well spent. A CEO has to commit time and effort to the program. If the CEO does not want to commit, the job will be much harder. ...
Compliance encompasses a broad range of ongoing activities across all departments or divisions within a company to meet legislative and regulatory requirements.
I may be getting cynical in my old age, but honesty is a rare thing these days. It seems to be getting more difficult to find honest people, especially when it comes to business. Each day we read about another scandal involving another fraudster, corrupt politician or criminal motivated by greed.
If an organization’s tone at the top could be measured and correlated with higher earnings and lower rates of financial reporting fraud... most directors would almost certainly want to assess that tone.
Risk oversight is a top-of-mind issue for boards because of the expectations spawned by the financial crisis and the unanswered questions around what directors might have, or should have, done to thwart that crisis.
If you’ve worked in a corporation for any length of time, you’ve lived through multiple initiatives designed to inspire, motivate and give direction to employees.
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.