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Trust and Integrity

The foundation of an ethical culture is trust and integrity. Employees are proud to work for organizations that prize trust and integrity. When senior leaders act in ways that are contrary to these values, employees’ belief in the company’s integrity plummets. The importance of tone at the top can’t be underestimated; failings in this regard are disastrous.

This article was republished with permission from Michael Volkov’s blog, Corruption, Crime & Compliance.

Humans have an innate desire to complicate things. When it comes to ideas, professionals are no different; compliance consultants, lawyers, financial advisers and others enjoy solving complicated problems. Such an approach, however, does a disservice to clients and other professionals.

Creating complications is not a sign of professional talent; rather, an effective consultant, attorney or financial adviser should be able to take complex issues, simplify the analysis and develop practical solutions that engage the client audience.

When it comes to creating and maintaining an ethical corporate culture, the solutions are not hard to define. The difficulty usually arises from the lack of commitment or understanding by a CEO and senior leadership. A chief compliance officer has to educate a company’s board, CEO and senior leadership about the important benefits of corporate culture and their critical role in promoting a company’s ethical culture.

This is not rocket science, as I like to say, but it requires board members, CEOs and senior executives to understand how to accomplish this task. Some leaders are natural communicators in this area and do not need to be guided, nor given talking points or scripts. We like to say they “get it.” These leaders make CCOs (and everyone else) look good when they speak off the cuff about the importance of the company’s values and its commitment to trust and integrity.

We all know that the foundation of an ethical culture is built on two important words: trust and integrity. Employees understand these terms, and when surveyed, respond most strongly to these two terms as guideposts for assessing corporate behaviors and values.

A CCO who does not work with a “natural” CEO in this area has to bring them along by pinning these two words (figuratively, not literally) on a CEO and reminding the CEO at every step to speak about the importance of trust and integrity.

Trust is an important requirement for corporate leaders, managers and employees. When a company is built on trust, employees feel proud of their company, the people that work there and the work they do. It is easier to work hard and commit oneself to an organization built on trust among its employees.

A company also has to commit to operating with integrity. Everyone wants to believe in the positive attributes of the organization in which they work. Government employees believe in the public interest mission of the agency or department in which they work. Private sector employees feel the same way and expect their leaders, as well as their colleagues and immediate supervisors, to act with integrity. When an employee witnesses his or her immediate supervisor acting contrary to this value, the employee’s belief system is challenged. When an employee reads about senior leadership’s involvement in a corporate scandal, the employee’s belief in the company’s integrity drops.

A company’s board, CEO and senior executives need to understand that trust and integrity are created not just by the words they use at company meetings or gatherings, but in their day-to-day activities. Words and actions are the means by which a corporate culture is created. When a company’s reputation for trust and integrity suffers, the company and all stakeholders suffer real and significant harms, both financial and emotional.

I have witnessed companies fall into various states of corporate culture. In my world of simplicity, it is not hard to see (and feel) a company’s corporate culture. It permeates throughout an organization and its employees. It is tangible, and it is real.

In the end, as I often repeat myself, a company’s culture is its best and most effective internal control. A company with an ethical culture is less likely to suffer employee misconduct and reputational harm than a company that has no commitment to an ethical culture.

Corporate leaders who ask themselves why they suffered a scandal or government enforcement action do not have to look far or stretch for an explanation – the answer usually lies in the company’s culture and the commitment of the board, the CEO and senior executives to promoting and maintaining the company’s commitment to trust and integrity.

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Michael Volkov

Michael Volkov

Michael-Volkov-leclairryanMichael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services.  He can be reached at  His practice focuses on white collar defense, corporate compliance, internal investigations, and regulatory enforcement matters. He is a former federal prosecutor with almost 30 years of experience in a variety of government positions and private practice.

Michael maintains a well-known blog: Corruption Crime & Compliance which is frequently cited by anti-corruption professionals and professionals in the compliance industry.Michael has extensive experience representing clients on matters involving the Foreign Corrupt Practices Act, the UK Bribery Act, money laundering, Office of Foreign Asset Control (OFAC), export controls, sanctions and International Traffic in Arms, False Claims Act, Congressional investigations, online gambling and regulatory enforcement issues.

Michael has assisted clients with design and implementation of compliance programs to reduce risk and respond to global and US enforcement programs.

Michael has built a strong reputation for his practical and comprehensive compliance strategies.Michael served for more than 17 years as a federal prosecutor in the U.S. Attorney’s Office in the District of Columbia; for 5 years as the Chief Crime and Terrorism Counsel for the Senate Judiciary Committee, and Chief Crime, Terrorism and Homeland Security Counsel for the Senate and House Judiciary Committees; and as a Trial Attorney in the Antitrust Division of the U.S. Department of Justice.

Michael also has extensive trial experience and has been lead attorney in more than 75 jury trials, including some lasting more than six months. His clients have included corporations, officers, directors and professionals in, internal investigations and criminal and civil trials. He has handled a number of high-profile criminal cases involving a wide‐range of issues, including the FCPA and compliance matters, environmental crimes, and antitrust cartel investigations in countries all around the world.

Representative Engagements

  • Successfully represented three officers of a multinational company in two separate criminal antitrust investigations involving a criminal antitrust investigation in the District of Columbia and the Southern District of New York.
  • Defended pharmaceutical company before the Food and Drug Administration and Senate Finance Committee relating to application for approval of generic drug.
  • Conducted internal investigation which exonerated company against allegations of false statements in submissions to the FDA and against improper conduct alleged by Senate Finance Committee.
  • Represented company before the US State Department on alleged violations of ITAR which lead to voluntary disclosure and imposition of no civil or criminal penalties.
  • Advised several multinational companies on compliance with anti‐corruption laws, and design and implementation of anti‐corruption and anti‐money laundering compliance programs.
  • Advised hospitals, pharmaceutical companies and medical device companies on compliance issues relating to Stark law and Anti‐Kickback law and regulations.
  • Conducted due diligence investigations for large multinational companies for anti‐corruption compliance of: potential third party agents, joint venture partners and acquisition targets in Europe, Africa, Asia and Latin America.
  • Represented individual in white collar fraud case in Alexandria, Virginia and secured dismissal of criminal charges and expungement of criminal record.
  • Represented company before Congress and Executive Branch in effort to modify Justice Department regulations concerning use of federal funds.
  • Advised and assisted World Bank in review of global corruption policies, enforcement programs and corruption investigations and prosecutions.

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