Day: May 5, 2020

31 Days to More Effective Compliance Programs

Code of Conduct

What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in regulator’s face during an enforcement action by using it to claim, “we are an ethical company”. Is such a legalistic code effective? Is a Code of Conduct more than simply your company’s law? What is it that makes a Code of Conduct effective? What should be the goal in the creation of your company’s Code of Conduct?
How important is the Code of Conduct? Consider the 2016 SEC enforcement action involving United Airlines, Inc., which turned on violation of the company’s Code of Conduct. The breach of the code was determined to be a FCPA internal controls violation. It involved a clear quid pro quo benefit paid out by United to David Samson, the former Chairman of the Board of Directors of the Port Authority of New York and New Jersey, the public government entity which has authority over, among other things, United Airlines operations at the company’s huge east coast hub at Newark, NJ.
The actions of United’s former CEO, Jeff Smisek, in personally approving the benefit granted to favor Samson violated the company’s internal controls around gifts to government officials by failing to not only follow the United Code of Conduct but also violating it. The $2.4 million civil penalty levied on United was in addition to United’s Non Prosecution Agreement resolution with the DOJ, which resulted in a penalty of $2.25 million. The scandal also cost the resignation of Smisek and two high-level executives from United.
Three key takeaways:

Every formulation of a best practices compliance program starts with a written Code of Conduct.
The substance of your Code of Conduct should be tailored to the company’s culture, and to its industry and corporate identity
“Document, Document, Document” your training and communication efforts around your Code of Conduct.

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Compliance Kitchen

Covid-19 and Global Trade

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Post date May 5, 2020
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In this podcast episode, we take a look at recent import and export developments in the US and the EU, plus one update on anti-trust in response to the corona virus pandemic.

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The Ethics Experts

TEE Bonus Episode 010: COVID-19 Edition with Tom Fox

Post author By ComplianceLIVE
Post date May 5, 2020
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On this special bonus episode of The Ethics Experts, we speak with Compliance Evangelist Tom Fox about how organizations can think ahead to determine the compliance aftermath of COVID-19.

Check out more episodes, and don’t forget to subscribe on your favorite podcast platform!

The Compliance Life

Ellen Hunt on How Do You Get There

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Post date May 5, 2020
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The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer. Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
In this first episode, we discuss how to start the journey to the CCO chair. We consider what it means to be in the compliance profession. How do you think about a career in compliance? What are some of the skills you will need to move forward in compliance?

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Compliance and Coronavirus

James Gellert on the Financial Health of Your Third-Parties

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Post date May 5, 2020
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Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by James Gellert, CEO of Rapid Ratings. We discuss the services provided by Rapid Ratings to help companies understand the financial health of their third parties and why in this time of Covid-19, such information is even more critical.
For more information on Rapid Ratings, check out their website by clicking here. Also, check out the Rapid Ratings Covid-19 Resource Center, available here.

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Innovation in Compliance

The Role of Wellbeing in a Thriving Culture with Mari Ryan

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Post date May 5, 2020
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Mari Ryan is the CEO of Advancing Wellness and author of The Thriving Hive: How People-Centric Workplaces Ignite Engagement and Fuel Results. She joins Tom Fox on this week’s show to discuss the role of employee wellbeing in a thriving business culture.

Assessing Wellness
Many of the concepts and strategies concerning ethical values and corporate culture that Mari espouses, says Tom, are the same that a compliance officer would use. He asks Mari how her company helps clients assess their employees’ wellbeing. She describes her two-part process: the first part is the qualitative and quantitative assessment, and the second part is creating a strategic plan to operationalize a culture of wellbeing in the workplace.
Wellbeing Is Crucial to Business Success
“Wellbeing can serve as a foundational element to the culture of the workplace and to creating business success… You need to have engaged employees to create a sustainable business,” says Mari. Wellbeing is physical, emotional, and financial; it involves feeling connected to your purpose and to other people. Mari adds, “If I’m feeling more thriving in my wellbeing, then I am more likely to be engaged, to be productive, to be connected to the purpose of the organization and making contributions that are going to make for happy customers, happy colleagues and help everybody achieve their business goals.”
Employee Wellbeing Is An Indicator of Organizational Culture
Mari posits in her book that employee wellbeing is an indicator of an organization’s culture. She tells Tom that culture is the behaviors, norms, assumptions, and rituals within the organization. Purpose and values work together to form culture. If employees feel cared for and that their wellbeing is considered, the culture will be healthy.
Wellbeing During and Post COVID-19
Tom asks how Mari is counseling clients during the crisis. She responds that during a crisis we have to think about things from a different perspective. Stress is the major issue that everyone, no matter their circumstances, is dealing with during the pandemic. We will also have to deal with stress post COVID-19, she points out. She outlines the various types of support people will need after the pandemic.
Resources
Mari Ryan on LinkedIn
AdvWellness.com