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Using Culture to Manage Complexity and Ethical Risk

Organizations must re-architect the context (culture) in which employees make decisions, simplifying ethical dilemmas and increasing ethical capacity. SAI Global’s Strategic Culture Framework provides a robust approach to achieving these objectives. Disruptive technologies, unexpected market shifts, widespread political uncertainty, conflicting stakeholder expectations and a host of other forces are reshaping today’s business landscape. Confronted with mounting challenges and unprecedented levels...

Dear CCOs: What is Your Mandate??

Dear CCOs: What is Your Mandate??

Detect, Fix or Prevent Problems Before They Become a Crisis Donna Boehme, the "Lion of Compliance," explains the singular imperative of a clear, written mandate for effective compliance programs, and offers a Sample Mandate, below. One of the most important features of any compliance program is its written Mandate. The correctly scoped mandate, approved by the Board and understood by...

When are Anti-Money Laundering Program Deficiencies a Crime?

When are Anti-Money Laundering Program Deficiencies a Crime?

Criminal Actions Brought Against Rabobank and US Bank Kerry Zinn identifies stipulations to evaluating anti-money laundering programs and the importance of cooperating with regulators.  In early 2018, the Department of Justice (“DOJ”) brought two criminal actions relating to Anti-Money Laundering (“AML”) program deficiencies. This article examines the criminal actions brought against Rabobank National Association (“Rabobank”) and US Bank National Association...

Auditing the Due Diligence Process

Given its tendency to be overshadowed by the more exciting aspects of the M&A process, internal auditors can contribute significant value by ensuring that a vibrant due diligence process is in place and operating as intended. A rigorous audit of the M&A due diligence process can help companies take advantage of legitimate new business opportunities, while at the same time...

Superstar Harasser

Superstar Harasser: Is Anyone Really Too Big to Lose?

Addressing Sexual Harassment In The #MeToo Era, Part 3 The #MeToo movement has brought to light allegations of misconduct by members of countless industries. As a result, in workplaces and on social media, we’re beginning to discuss in earnest what constitutes workplace harassment and employers’ obligations to combat it. In the third installment of this four-part series from Vedder Price’s...

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Key Challenges for CECOs

Justifying the Role to Strengthen the E&C Function Compliance as a profession continues to grow globally. Compliance departments expand in response to every corporate scandal. Following increased regulatory scrutiny, the chief ethics and compliance officer role is becoming more elaborate and sought-after. However, inside organizations, CECOs still face a number of challenges. Vera Cherepanova offers practical ways to address concerns...

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The True Test of an Effective E&C Program

Follow the Resources How do you know whether your ethics and compliance program will succeed? One surefire way to gauge its potential efficacy is to see just how well equipped it is to do the job at hand. Does your compliance team have the manpower and budget it needs? An effective ethics and compliance program depends on the Chief Compliance...

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Workplace Dynamic: How Disrespect Can Quickly Become Harassment

EEOC’s New Civility Training Shows How Thin The Line Really Is Workplace harassment has dominated the headlines of late. NAVEX Global Vice President Ingrid Fredeen discusses the importance of culture and training, and how incivility has been described as “the gateway drug” to harassment in the workplace. The Equal Employment Opportunity Commission recently announced a new training program on “respectful...

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France Cracks Down on Corruption with New Law

Bienvenue, Sapin II The introduction of Sapin II adds to the growing list of laws aimed to reduce corporate corruption. While these laws are important and beneficial, they cannot improve corporate culture to the extent that high-quality ethics and compliance programs do. To that end, every organization should prioritize internal ethical culture while complying with the law. By now, the enactment...

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How to Integrate a Compliance & Ethics Program with a Control Framework

Leveraging COSO’s Internal Control – Integrated Framework Cultures may vary widely, but all organizations should be proactive about building and maintaining a culture of compliance. The COSO Integrated Framework provides extensive guidance on how to accomplish this. Ron Kral offers insights on integrating your company’s C&E program with a control framework. While many organizations have a compliance and ethics program...

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