Day: April 13, 2020

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31 Days to More Effective Compliance Programs

The Integrity Audit


Yet another way to consider using audit for continuous improvement is through the Integrity Audit. Mary Jo White in an article entitled “What I’ve Learned About White Collar Crime” provided insight into not only white-collar criminals but the integrity of companies. Her framework lays out a way for you to think through an underutilized tool for continuous improvement, the integrity audit.
When Mary Jo White or Jonathan Marks write, you need to read, digest what they have to say and implement their suggestions. The ideas that they forward are not new, revolutionary or in the least bit controversial. Yet integrity is not often considered by compliance professionals. With the Business Roundtable’s Statement of Corporate Purpose integrity has been driven to the forefront in the rasion d’etre of a corporation. Failing to have integrity at the top or down through your organization can lead to significant corporate calamity.
Three key takeaways:

  1. The Integrity Audit is an underutilized tool.
  2. Ego and arrogance at the CEO level can lead to catastrophic corporate failures.
  3. A robust report culture can demonstrate and facilitate corporate integrity.
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31 Days to More Effective Compliance Programs

The Culture Audit


What is organizational culture? Eric R. Feldman, SVP at Affiliated Monitors Inc. (AMI), has said it comprises the mission, vision and values of an organization. A similar way to consider it might be as a company’s values, visions, norms and beliefs. Whichever way you define it or look at it, corporate culture affects how groups within a company interact with each other. A key inquiry is whether the corporate incentive structure supports the articulated beliefs of a company. How does one measure or audit these articulations?
Companies must have a high-performance corporate culture for doing business ethically. One of the ways to do so is through the culture audit. It can also be a powerful tool for continuous improvement going forward. Find out what your employees are saying about your corporate mission, vision and values and most importantly remediate if those mission, vision and values are found wanting.
 Three key takeaways:

  1. What are the mission, vision and values of a company?
  2. What are the compensation and promotion incentives in the culture?
  3. Is your motto “Always be closing” or closer to “doing business ethically and in compliance”?
Categories
Daily Compliance News

April 13, 2020-the Wordsworth edition


In today’s edition of Daily Compliance News:

  • What will the English do? (FT)
  • Sometimes the least worst option is the best? (FT)
  • Why is Boeing fighting transparency? (FT)
  • How Wordsworth informs work from home. (FT)
Categories
FCPA Compliance Report

James Koukios on the MoFo Top 10 International Anti-Corruption Developments for February 2020


In the Episode, I visit with James Koukios, partner at Morrison & Foerster, Editor-in-Chief of the firm’s Top 10 International Anti-Corruption Developments. We visit about the firm’s Top 10 International Anti-Corruption Developments for February 2020. Some of the highlights include:

  1. Lambert Motion for Acquittal Denied. We take a deep dive into the motion and the court’s ruling.
  2. Pemex Investigation Expands. What does it mean for US companies?
  3. Is each email a separate FCPA violation? What does this mean for the DOJ going forward?
  4. Cardinal Health FCPA resolution. Key takeaways for the compliance professional.

 Resources
To a copy of the Top 10 International Anti-Corruption Developments for February 2020 Newsletter click here.