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The Ethics Experts

Episode 010–Micah Soloman

On this episode of The Ethics Experts, we speak with Micah Solomon about customer service excellence: how to achieve it, how to maintain it, and how to stand out from a crowd.

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31 Days to More Effective Compliance Programs

Continuous Improvement Through Compliance Program Upgrades


Continuous improvement can come in many different, shapes, sizes and packages. As with all things compliance, you are only limited by your imagination. Have you ever thought about a tech implementation as a way for continuous improvement? Probably not but it is also a way forward for continuous improvement. Think about that for a moment as this is taking the concept of continuous improvement and adding an ongoing tech solution. This is one of the areas both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) discussed in their jointly issued 2012 FCPA Guidance, as Hallmark 9 in the Ten Hallmarks of an Effective Compliance Program. This is not simply taking data from your compliance program and feeding it back in to create continuous improvement, but it is using a tech solution to not only make your compliance program run more efficiently but using that same tech solution to help continuously improve your compliance program.
Such an approach uses the subject matter expertise (SME) of the tech solution provider to help the compliance professional come up with a more effective compliance program. For the compliance professional it is expanding out their reach and scope through the use of not only this tech SME but with the information from their own compliance program to create greater efficiencies and effectiveness.
 Three key takeaways: 

  1. Even in continuous improvement, you are only limited by your imagination.
  2. The delivery of a tech solution for compliance can be beneficial in multiple ways.
  3. Start your analytics at the transaction level and move upwards.
Categories
FCPA Compliance Report

From the Unthinkable to a Culture of Compliance-How a Car Wash Changed a Culture, Isabel Franco


In this special podcast series, I visit with lawyers from Azevedo Sette in Sao Paulo. The lawyers and topics include: Isabel Franco on a CarWash changed a culture, Lucas Bianchinni on environmental regulation in Brazil, Glaucia Ferreira on the Clean Companies Act, Luiz Salles on recent Brazilian corruption enforcement actions and Ingrid Santos & Guiliana Boniha on the hottest topic in Brazil: Me Too and sexual/moral harassment. In this first episode, I chat with Isabel Franco about how CarWash changed the entire perception and culture of compliance in Brazil.

  1. What was CarWash and how did it change perceptions about compliance in Brazil?
  2. Why was an investigation of corruption of Petrobras so critical to Brazil?
  3. Who were some of the key political figures brought down by Lava Jato?
  4. Why was this change so critical to the compliance profession in Brazil?
  5. What other corruption investigations did CarWash lead to?
  6. How did Lava Jato expand out to the entire continent?
  7. Having practiced in both the US and Brazil, how would you assess the current state of the compliance profession in Brazil?
  8. What is the legacy of Lava Jato?

This podcast is sponsored by the law firm of Azevdo Sette. To learn more about this firm, visit its website, for resources, expert guidance and support.

Categories
FCPA Compliance Report

Susan Divers on LRN’s 2020 Compliance Program Effectiveness Report


In the Episode, I visit with Susan Divers, Senior Executive at LRN. Susan is one of the leaders of the LNR team which annually produces the Program Effectiveness Report. The 2020 version has been released. We review its key findings and insights as well as the LRN Program Effectiveness Index. Finally, we conclude with a key theme of the Report and discuss why it is such an insight for the compliance professional.
Some of the highlights include:

  • What is the 2020 Program Effectiveness Report?
  • Why does LRN release this report annually?
  • This year’s report has even more importance and urgency but we had ethical failures which caused loss of life over the past year as well?
  • What were the overview of key insights?
  • What are some of the key reasons ethical scandals occur?
  • What is the Program Effectiveness Index (PEI) and what does it tell us this year?
  • What are the 5 elements of an ethical culture?
  • One of the key themes I took away from this year’s Report is the interconnectedness of compliance program elements.

Download and read the 2020 Program Effectiveness Report here. For more information on LRN, click here.LRN
 

Categories
Daily Compliance News

April 27, 2020-the Worker Health edition

In today’s edition of Daily Compliance News:

  • Boeing pulls the plug on deal with Embraer. (NYT)
  • Did Huawei do business in Iran? (NYT)
  • FCPA enforcement here to stay. (WSJ)
  • Will Trump Administration gut worker health safety?(WaPo)