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Venice and How the Lion’s Mouth Informs Your Hotline

This week we will have a short series based upon themes from Venice. The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens could report misconduct. A citizen could write down his concern on paper and literally put the message into the mouth of statues of lion heads placed around the City. This system was originally set up to be anonymous but later changed to require that a citizen had to write his name down when submitting a message.

So, once again, using Venice as inspiration for a compliance topic, today I would like to review some best practices regarding a compliance hotline.

Get the word out. Allocate a portion of your time and budget to promoting the corporate hotline through multiple channels. Deliver in-person presentations where possible. Do not think of the promotional initiative as a one-time effort. It is important to remind employees regularly, through in-person communications, via e-mail, or through intranets, newsletters, and so on, that this resource is available to them.

Train all your employees. Getting employees to use the system is one half of the challenge; ensuring they use it properly is the other half. This is where training becomes essential. Make sure people understand what types of activities or observations are appropriate for reporting and which are not. Company leaders also need to understand the role the hotline plays in the organizational culture, and the importance of their visible support for this compliance initiative.

Take a look at the data. Use the data derived from or through the hotline to identify unexpected trends or issues. Isolate the data by location and department to identify micro-trends that could indicate problems within a subset of your corporate culture. Analyzing the data can help you stay a step ahead of emerging issues.

Response is critical to fairness in the system. Seeing a hotline system in action in this way can go a long way toward dispelling employee fears of being ostracized or experiencing retaliation because if they see that their concerns are heard clearly and addressed fairly, they will learn to view the hotline as a valuable conduit. If your compliance group responds promptly and appropriately to hotline complaints, you can ensure robust participation and ongoing success.

I am reminded how much the western world has to thank the Republic of Venice. From the forms of republican democracy that the US Founding Fathers drew from to helping to establish a world-wide trade and banking system which still reverberates today. But, if you look closer, ancient Venice had many good government techniques which also still inform the modern world. Straight from the lion’s mouth to your company’s compliance hotline is just one of them.

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EMBARGOED!

EMBARGOED! Episode 56: China Redux: What Could Be Lurking in the Supply Chain

In this episode, Tim is joined by Kate Yin (Fangda Partners) and Miller & Chevalier’s Richard Mojica and Virginia Newman to discuss due diligence and other issues arising from the newly implemented Uyghur Forced Labor Prevention Act. The group walks through the basics of the UFLPA, the challenges it creates for U.S. importers, the industries it targets for enforcement, and the rebuttable presumption for items traced to Xinjiang province.  The group then turns to identify concrete steps companies are taking to comply with the UFLPA, including how companies are conducting necessary due diligence while at the same time navigating challenges posed by Chinese Anti-Foreign Sanctions law.

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Questions? Contact us at podcasts@milchev.com.

EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.

***Stay sanctions free.***

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The Ethics Experts

Episode 136 – Mara Senn

In this episode of The Ethics Experts, Nick welcomes Mara Senn. Mara V.J. Senn is currently a Director and Senior Counsel for Global Compliance Investigations at Zimmer Biomet conducting investigations all over the world with a particular focus on Latin America. She was previously a Senior Investigator and Senior Litigation Specialist at the Integrity Vice Presidency at the World Bank where she investigated allegations of corruption, fraud, collusion, obstruction and coercion in World Bank-financed projects around the world.

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FCPA Compliance Report

David Simon and Mike Walsh on Global Supply Chain Disruption and Compliance, Part 2

In this episode, I visit with Foley & Lardner partners David Simon and Mike Walsh on the disruption to the global supply chain, which I focused on in the podcast series, Never the Same. They have co-authored an article entitled,  Managing Supply Chain Disruption in an Era of Geopolitical Risk on the topic. In this Part 2 of a two-series, we continue our exploration of the current global supply chain and focus on issues relating to China.

Some of the highlights include:

·      Why ever company should prepare for a China confrontation over Taiwan.

·      Is the UFLPA a true game changer for supply chains and compliance?

·      What is the impact of China’s Belt and Road program? It’s debt financing?

·      Why is the global supply chain and indeed the global economy of the past 30 years now dead?

·      What steps compliance functions should take now around the global supply chain of the future.

 Resources

David Simon

Mike Walsh

Managing Supply Chain Disruption in an Era of Geopolitical Risk by Mike Walsh and David Simon

Why Supply Chain Will Never Be the Same After the Russian Invasion by Tom Fox

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Daily Compliance News

November 21, 2022 the Schooled in Corruption Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you four compliance related stories to start your day. Sit back, enjoy a cup of morning coffee and listen in to the Daily Compliance News. All, from the Compliance Podcast Network.

Stories we are following in today’s edition of Daily Compliance News:

  • FIFA President defends Qatar. (WSJ)
  • Special prosecutor ‘schooled in corruption”. (NYT)
  • Former Pakistani PM denies receiving $2MM in bribes. (The Guardian)
  • Twitter employee exodus increases. (FT)