Categories
The Ethics Movement

Converge20-Jenny Kim- How Behavioral Science Powers Empathetic Workplace Policies


CONVERGE is in its 5th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. This year the conference has gone virtual. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Jenny Kim. We visit about her presentation at Converge20 on How Behavioral Science Powers Empathetic Workplace Policies. 
When you take human behavior into account at the center of your procedures, processes, and systems, you’ll minimize opportunities for misconduct, reduce risk, and make it possible to write more empathetic, human-focused policies. Join this session to learn how behavioral science and human-centered focus will allow you to:
-Maximize good decision-making and reduce risk
-Build systems that mitigate opportunity for misconduct
-Create empathetic, human-centered policies that are good for business and good for your workforce.
For more registration and information on Converge20, click here.

Categories
31 Days to More Effective Compliance Programs

COSO Objective I: Control Environment


The first of the five objectives is control environment and it sets the tone for the implementation and operation of all other components of internal control. It begins with the ethical commitment of senior management, oversight by those in governance, and a commitment to competent employees. The five principles of the control environment object are as follows:
Principle 1: Commitment to integrity and ethical values.
Principle 2: Board independence and oversight.
Principle 3: Structures, reporting lines, authority and responsibility.
Principle 4: Attracting, developing and retaining competent individuals.
Principle 5: individuals held accountable.
Discussion. Both Board of Directors’ independence and Compliance Committee (or other applicable committee) oversight are essential to this objective because the committee needs to be actively engaged to be comfortable that the company has implemented the internal controls under SOX 404(a); as required under Principles 1 and 2.
Under Principle 3, structures in reporting lines, authority and responsibility are essential to the recognition of revenue. Under Principle 4, a business must attract and develop, then retaining competent talent. This ties into Principle 5, which mandates individuals being held responsible. This requires someone to document that they have made a judgment based upon the evidence that they have been able to accumulate, that the company has analyzed that evidence and has gone through the process of comparing this to the COSO 2013 Internal Controls Framework and to the spirit of the standard. 
Three key takeaways:

  1. What controls do you have in place to measure conduct at the top?
  2. Reporting lines must be clear and functioning.
  3. You must provide the right personnel with the right resources.
Categories
The Ethics Experts

Episode 029–Christian Hunt

On this episode of The Ethics Experts, Nick speaks with Christian Hunt about compliance policies, how strict we should be with them, and how not all policies are created equal.

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

Categories
FCPA Compliance Report

John Fons and Current Issues Facing CCOs


In this episode, I visit with John Fons. Over his career, Fons has been the Director, Global Compliance & Ethics, Modine Manufacturing, Senior Counsel, Modine Manufacturing, General Counsel, Joy Global, Milwaukee and VP, General Counsel & Secretary, Metso Minerals, Brookfield. Fons has also been a Partner to the Board and all levels of organization in setting strategic direction of ethics and compliance program and implementation within businesses. Fons provides insights into some of the current issues facing CCOs and CECOs today.
Some of the highlights include:

  • Why compliance needs to report into a Board committee separate and apart from the Audit Committee;
  • Why Boards should have compliance expertise on the Board;
  • Why CCOs should have a written contract with guaranteed severance; and
  • Why the hiring and firing of CCO should be an 8K event.
Categories
Daily Compliance News

September 21, 2020-the Banks Behaving Badly, Part 385 edition


In today’s edition of Daily Compliance News:

  • Banks and SARs. (NYT)
  • HSBC allowed Ponzi scheme. (BBC)
  • Cache of FinCen docs made public. (BBC)
  • US court blocks ban of WeChat. (FT)