Categories
Jamming with Jason

JwJ Encore: Get Out of Your Head


In today’s #jammingwithjason #podcast episode, we will talk about how overthinking and getting into your head may be one of the worst things you are doing.
There are certain things that you can do to improve your habits which will, in turn, improve your outcomes in life.
So join me here on the podcast, where I will share some of these little life “hacks” with you so you can quit overthinking and start living!
Listen in at: https://www.jasonmefford.com/jammingwithjason136/.

Categories
Compliance Kitchen

EU’s 4th Package of Sanctions


The Kitchen reviews the EU’s 4th package of sanctions on Russia.

Categories
Career Can D0

The ‘We’ Mentality with Andrea Sanchez


 
In this episode of Career Can Do, Mary Ann Faremouth chats with Andrea Sanchez. Andrea is Director of Communications at ENGIE North America, where she oversees internal and external communications efforts for over 1600 employees. She is also Community Ambassador at HumansFirst, and Executive Director at SparkStory. Andrea works with a humanitarian effort to create a more harmonious work environment and bring a ‘we’ mentality to corporate culture. She talks about human connection in the workplace, and how she is creating spaces for authenticity. 
 

 
All workplaces start with people, but we tend to lose sight of that because we focus so much on business, Andrea shares. The people are what make workplaces successful, and when it comes to people, emotions are key. The more we can have respect, understanding, and compassion for others, the better we are going to be and the bigger contribution we’re going to be able to make, Mary Ann adds.
 
Andrea started her online rally, initially called A Rally for Equality, as a way to spread good amidst the social unrest of June 2020. Since then, it has exploded into a vehicle for authenticity, kindness, and connecting with other people. “It grew to be more like A Hope and Kindness Rally, and I call it that because I want to remind people that there is hope regardless of what you’ve been through, and we show up because we want to be kind to each other,” Andrea says.
 
Resources
Faremouth.com
 

Categories
The Hill Country Podcast

Michele Van Fossen-Pop Hair Art and Acting in Kerrville


Welcome to The Hill Country Podcast. The Texas Hill Country is one of the most beautiful places on earth. In this podcast, recent Hill Country resident Tom Fox visits with the people and organizations that make this the most unique areas of Texas. Join Tom as he explores the people, places and their activities of the Texas Hill Country.  In this episode, I visit with Michele Van Fossen, owner of the Pop Hair Art Salon, in Kerrville. Michele and her family moved to the Hill Country 9 years ago and Michele has been very active in both the local business environment and the local theater scene.
Some of the highlights include:

  • Why Michele and her husband moved to the Hill Country.
  • How she pays it forward for younger hair stylists.
  • Her theater career in the Hill Country, including her favorite roles.
  • The Popettes.
  • Soft skills and hard skills in the Salon business.

Resources
Pop Hair Art Salon
Pop Hair Art Salon on Facebook
Pop Hair Art Salon on Instagram

Categories
Compliance Into the Weeds

Proposed SEC Climate Change Risk Disclosure Regulations Released


Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a look at the proposed SEC climate change risk disclosure regulations released on Monday. Highlights include:

  • The history of this issue.
  • Is the SEC over-reaching?
  • Why climate change regulations only? What about a broader set on ESG?
  • The role of internal controls, audit and oversight.
  • What does all this mean for the compliance function?

Resources
Matt Kelly in Radical Compliance

Categories
Daily Compliance News

March 23, 2022 the Corruption in Gotham Edition


In today’s edition of Daily Compliance News:
·      Why is Gotham City so corrupt? (MovieWeb)
·      SEC announces climate change risk disclosure regs.   (Kerrville Daily Times)
·      Anti-corruption judge from Guatemala resigns and flee country.  (NBC)
·      Sunny Balwani trial begins.  (WSJ)

Categories
Blog

Sales incentives and Compliance

Sales incentives continue to be an area where Chief Compliance Officers (CCOs) and compliance professionals work refine their compliance regimes. In the 2020 Update to the Evaluation of Corporate Compliance Programs (Update), Incentives and Disciplinary Measures, the Department of Justice (DOJ) stated:

Incentive System — Has the company considered the implications of its incentives and rewards on compliance? How does the company incentivize compliance and ethical behavior? Have there been specific examples of actions taken (e.g., promotions or awards denied) as a result of compliance and ethics considerations? Who determines the compensation, including bonuses, as well as discipline and promotion of compliance personnel?

When considering how a company could use incentives to further a compliance program, and the role of HR in this process, we should also consider how incentives might lead to the converse, as they did in the now-infamous Wells Fargo fraudulent-accounts scandal. When you misalign these two concepts with a faulty sales strategy it can lead to a catastrophic failure, literally costing the company millions of dollars in fines, loss of business, and depreciation of shareholder value.

The sales incentives under which Wells Fargo came to such grief is a simple, and even benign, story of the cross-selling of products. After all, large banks cross-sell their clients all the time, and nobody seems to blink an eye at the cross-selling McDonalds engages in every time you buy a Big Mac when the representative asks if you would like fries with it. Yet there are other reasons for engaging in this type of business practice. Each and every time a company has a touchpoint, particularly a commercial touchpoint, with a business, it strengthens the relationship.

At Wells Fargo, however, what started off as a legitimate, legal and beneficial business strategy became not only high-risk, but illegal because of the manner in which Wells Fargo administered its approach to cross-selling. As with any sales initiative, if a company wants to push cross-selling, it will set up incentives for encouraging the sales team to engage in such behavior. This can be done by increasing commissions around the service or product being emphasized, such as the bank’s products. Companies can also increase sales by making clear that you will be evaluated on how much you sell a product or service. In other words, whether you receive a bonus, pay raise or even keep your job will be evaluated, in some part, on how much you cross-sell.

You can even have a hybrid of the above, which may be the worst of all worlds. At Wells Fargo, employees were evaluated for continuing employment by supervisors on cross-selling. Yet the employees did not receive the same financial incentives as the supervisors to make such cross-selling. Branch managers and supervisors could receive bonuses of up to $10,000 per month for meeting cross-selling quotas, whereas employees who hit their monthly quotas received, in addition to continued employment, $25 gift cards.

What about variable compensation? That is compensation based on alterable factors such as total sales, sales relative to a region, product line or other group. Some of the questions you might ask are: What does your bonus program consist of? Is it corporate performance based? Is it group performance based? Personal as in “eat what you kill”? Or is it some combination of all of the above?

A variable system can also lead to ethics and compliance failures. One reason could be similar to Wells Fargo—very high goals but no direction for employees on how to get there, coupled with a lack of communication between management and line employees, meaning there was raw fear from employees to inform their immediate supervisor of bad news. Conversely, it could be the supervisors who do not want to hear such bad news—for example, if your company has singular focus on numbers, meaning that is the single judge of your worth as an employee. Answering some of these questions if they arise can help you to understand the design of incentive plans and allow monitoring of incentive plans to identify underlying links that may arise through compliance violations.

Whatever your incentive structure, there will be employees who try to game the system. Some will do it with the tacit or explicit approval of management. You, as the CCO, may be required to act.