Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program for 3rd Parties – Risk Ranking in the Supply Chain

One of the areas many companies do not focus on enough is possible corruption in their supply chain for goods and services provided on a company’s behalf. The FCPA risks can be just as great through those entry points as they can be through the sales side of an organization. You need to know whom your company is doing business with through this channel as much as you need to know your agents seeking business opportunities on your behalf. Most companies have exponentially more vendors than sales agents, so this task may seem daunting. However, a well-thought-out plan to risk rank your company’s third parties on the supply chain side can go a long way toward ameliorating this issue. The key is setting reasonable parameters and then managing those third parties that present real corruption risk to your organization.

This determination of the level of due diligence and categorization of a supplier should depend on a variety of factors, including such factors as whether the supplier is (1) located or will operate in a high-risk country; (2) associated, or recommended, or required by, a government official; (3) currently under corruption investigation, or has been recently convicted of any form of corruption; (4) a multinational publicly traded corporation with a recognized exemplary system of compliance and internal controls; or (5) a provider of widely available services and products that are not industry specific. You should note that any supplier with foreign government touchpoints should move up to a higher level of scrutiny.

I suggest that you create a three-tiered risk matrix consisting of (1) high-risk suppliers, (2) low-risk suppliers, and (3) minimal-risk suppliers. Below this final category is another category for providers of goods that are commonly available and pose almost no corruption risk.

It would be best to risk ranking the third parties your supply chain might engage with for FCPA exposure. It should be based on your company’s experience and risk going forward. As with all third-party risk management issues, you must “Document, Document, and Document.”

Three key takeaways:

  1. Risk rank your supply chain based on well-conceived strata.
  2. Consider not only the compliance risk but also your business risk.
  3. Only manage those suppliers who present a corruption risk.
Categories
Daily Compliance News

April 27, 2023 – The De-Risking Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

Stories we are following in today’s edition:

·       De-risking bank customers.  (WSJ)

·       UK blocks Activism/Blizzard merger.  (NYT)

·       Jury begins deliberations in ComEd corruption case. (Chicago Sun Times)

·       Former Eskom CEO refuses to name names. (FT)

Categories
Hill Country Authors

Hill Country Author’s Podcast – Julia Daily – “No Names to be Given”: An Author’s Journey Through Adoption

Welcome to the award-winning The Hill Country Authors Podcast. In this podcast, Hill Country resident Tom Fox visits with authors who live in and write up the Texas Hill Country. In this episode, I visit  Julia Daily, our first Fredericksburg author on the show. She shares her diverse professional background in public relations, teaching, and being the executive director of Craftsman’s Guild of Mississippi. Julia gets personal and talks about her experience writing her recent book, “No Names To Be Given,” based on her own adoption story. Tom and Julia then delve into the shame and secrecy surrounding pregnancy out of wedlock in the 1900s. Julia shares her adoption story and how it inspired her to write about three women forced to give up their children for adoption. She also discusses her second book, The First Daughter of Thorn Ranch.

The podcast is thrilling and explores family dynamics, conflict, and conservation. The lively conversation includes Julia’s writing process, how she researches, and her upcoming projects, including a possible third book in her series. Additionally, the podcast discusses Julia’s interesting podcast that celebrates the success of authors who publish their first book after age of 50. This episode is sure to keep you engaged and wanting more.

Key Takeaways:

·      The Shameful Treatment of Unwed Pregnant Women

·      Women in Texas Ranching

·      Preserving Generational Ranches in Texas

·      Julia’s Writing Process and Research Methods

·      Julia on script writing and podcast promotion

 Resources

Julia Daily

Purchase No Names to Be Given

Purchase The Fifth Daughter of Thorn Ranch

Categories
Fox on Podcasting

Fox on Podcasting – Pat Cheung on the UX in Podcasting

Sometimes you have to go meta. After having recorded, produced, hosted, and guested in over 5000 podcasts, Tom Fox decided it was time to have a podcast about what else–podcasting. In this podcast series, Tom will visit with podcast hosts to learn about their love of podcasting, what they have achieved through podcasting, and why they need to consider starting their podcast. Fun, witty, and chatty with a dash of joie de vivre, this series will be entertaining and educational. Join Tom Fox as he explores the world of podcasting, and get ready to be inspired to start your podcast.

In this episode, Tom interviewed Pat Cheung, a UX designer who co-founded the startup, PodInbox, to solve problems he noticed in the podcasting world. Pat shared his professional background and how he built products, ran engineering teams, and founded a healthcare startup that eventually got acquired. After the acquisition, Pat shifted his focus to podcasting and noticed that podcasters wanted to hear back from their audience more easily, but there was a challenging solution. Tom and Pat discussed how some podcasters would direct their listeners to record their audio messages and email them or use a personal phone number to receive voicemails, which could be more social and user-friendly. If you want to learn more about how Pat Cheung solved the communication problem between podcasters and their audience, check out the episode.

Pat also talks about creating a micro podcast conference, PodConf, which will be held in Portland on April 29th. Check out the link below.

Key Highlights:

1. Engage with your audience by using a tool like PodInbox, which allows your listeners to leave voice messages and start conversations with each other.

2. Make it easy for your listeners to reach out to you by using a tool that lets them contact you directly, like a social media page or email.

3. Encourage your listeners to provide feedback and participate in the conversation to foster a sense of community.

Notable Quote:

“And I eventually built this startup called PodInbox, which the problem I was trying to solve with PodInbox was that I noticed many podcasters I was listening to wanted to hear back from their audience, and there was not a very easy way to do it.”

Resources:

Pat Cheung on LinkedIn

Podinbox

PodConf

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Compliance Week Conference Podcast

Doug Hileman on The Intersection of ESG & Compliance – Tactical Insights for Compliance and Risk Professionals

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, Doug Hileman discusses some of his panel at Compliance Week 2023,  “The Intersection of ESG & Compliance – Tactical Insights for Compliance and Risk Professionals .”

Some of the issues he will discuss in his presentations are:

  • The enforcement landscape, including SEC climate disclosure rule, code of conduct, etc.
  • The regulatory landscape
  • Keys to focus people, process, and technology supporting ESG efforts reporting and issues facing the corporate board
  • The COSO report

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 at the JW Marriott in Washington, DC. The line-up of this year’s event is simply first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 18th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. And many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.