Compliance

Volkswagen factory in Chattanooga, TN

4 Lessons from the Volkswagen Emissions Scandal

Volkswagen’s scandal around its false emissions data and the barrage of headlines that go with it underscore the importance of managing compliance risks and integrity in companies of all sizes. Although the scandal prompted questions about the company culture, it also highlights the difficulty of locating risk across an organization.

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Why Your Company Should Have Zero Tolerance for Zero Tolerance

Zero-tolerance policies may sound good on paper, but there are endless examples of how zero-tolerance policies have been applied to absolutely absurd effect. Robert Zafft offers an alternative approach for corporate compliance programs – one that takes the focus off of severe penalties and instead stresses continuous improvement in processes and corporate culture.

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Outrageous Compliance, Part 3

If everyone is responsible for managing risk at your organization, you’re probably in for a bumpy road. Senior leaders have a different perception of what’s most critical than do front-line staff, so their approaches to risk management would naturally be quite different. It’s best to leave the job of risk discovery, assessment and mitigation to the pros.

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The Panama Papers: What You Need to Know

On Sunday the world got a peek into how and where the ultra rich and dozens of current and former world leaders hide their wealth, and the fallout has already begun. Given the ethical implications of being outed in the leaks, government officials and leaders at organizations including FIFA and Transparency International who’ve been named are coming under fire.

Cybersecurity in 2022: More Acceleration, More Sophistication

Outrageous Compliance

Risk and compliance self-assessments aren’t the truest indicators of actual risk exposure. So you could say there’s an inherent risk in performing a risk self-assessment. Not only is there no real science behind them, the outcome of an RCSA is entirely subject to one’s memory. A self-assessment can be a good jumping-off point, but it can’t be your sole method...

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The Importance of Understanding Corrupt Intent

When faced with an allegation of corruption and a related investigation, your organization will be better protected by a strong compliance program – and one that requires staff to document their actions, reasoning and good faith effort to act in keeping with the law and the program. Proving corrupt intent can come down to inferences, and it’s best not to...

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What the Olympus Corporate Integrity Agreement Can Teach Us

Olympus, the world’s largest manufacturer of optics products, has demonstrated that its culture of corruption is endemic. Having violated the FCPA, the anti-kickback statute and the False Claims Act in a bribery and kickback scandal stretching back several years, the corporation has entered into a strict corporate integrity agreement aimed at ensuring Olympus has an effective anti-corruption compliance program going...

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Lessons From Qualcomm

Having violated the accounting provisions of the FCPA on several occasions, Qualcomm has been the target of an SEC investigation for some time. Last week the regulatory body concluded its enforcement action against Qualcomm, and there are some key lessons to be learned for the compliance practitioner.

DALL·E 2023-02-16 13.18.43 - magritte style painting of robot looking into mirror

What Good Compliance Looks Like

To elevate “compliance” from an overused buzzword to a real value and operational commitment, leadership must empower their front-line employees to broadcast the organization’s message of ethics and compliance, and trust them to do it.

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The VW Scandal

Volkswagen most certainly made a mess of things when they engineered a device to cheat emissions test, but they’ve bungled their part in the investigation as well. Thanks to the actions of some of the company’s top brass, VW has even further damage to its own reputation. The takeaway for the CCO: look at VW as a clear lesson in...

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