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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program: Day 6-Six Core Principles for Compliance Incentives

In these podcast episodes, Tom Fox discusses the importance of incorporating incentives and support systems into a company’s compliance program. He presents six core principles for effective compliance incentives, emphasizing the need for simplicity, visibility, and institutional mechanisms to ensure their longevity. Fox also highlights the role of human resources in implementing compliance programs and the positive impact it can have on organizations. By understanding and implementing these principles, companies can create a culture of compliance, reduce the risk of unethical behavior, and enhance their credibility.

I have developed six core principles for incentives, adapted from a MIT Sloan Management Review article, entitled “Combining Purpose with Profits”, and formulated them for the compliance function in an anti-corruption compliance program.

1.     Compliance incentives don’t have to be elaborate or novel.

2.     Compliance incentives need supporting systems if they are to stick.

3.     Support systems are needed to reinforce compliance incentives.

4.     Compliance incentives need a “counterweight” to endure.

5.     Compliance incentive alignment works in an oblique, not linear, way.

6.     Compliance incentive initiatives can be implemented at all levels.

Obviously, this list is not exhaustive. Yet it is now more important than ever that you demonstrate tangible incentives for your employees to gain benefits, both financial and hierarchical, through doing business ethically, in compliance with your own Code of Conduct and most certainly in compliance with relevant anti-bribery laws. It is also a requirement that such actions be documented so they can be demonstrated to the regulators, if they come knocking.

Three key takeaways:

  1. Compliance incentives do not have to be elaborate or novel.
  2. You must create support systems for your compliance incentives.
  3. Compliance incentives should be implemented at all levels.
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Trekking Through Compliance

Trekking Through Compliance: Episode 68 – Elaan of Troyius

 

In this episode of Trekking Through Compliance, we consider the episode Elaan of Troyius, which aired on December 20, 1968, and occurred on Star Date 4373.5

Kirk and crew are playing taxi to Elaan from Elas and an ambassador from Troyius. (She is one of the greatest spoiled brat characters in all of TOS.) Their mission: get everyone safely from point A to point B. Sounds easy, right? Now add in Elaan’s near-barbarism, a bit of sabotage, and a hostile Klingon ship. Can Kirk civilize Elaan, evade the Klingons, and keep the Enterprise from blowing up?

Compliance Takeaways:

1.     Do you perform continuous monitoring of your 3rd parties?

2.     How deep does your 3rd party investigation go?

3.     How culturally astute is your compliance regime?

Resources

Excruciatingly Detailed Plot Summary by Eric W. Weisstein

MissionLogPodcast.com

Memory Alpha

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Data Driven Compliance

Data Driven Compliance: Anselmo Guevara on Harnessing Data Analytics & AI for Compliance

Are you struggling to keep up with the ever-changing compliance programs in your business? Look no further than the award-winning Data Driven Compliance podcast, hosted by Tom Fox, which is a podcast featuring an in-depth conversation around the uses of data and data analytics in compliance programs. Data Driven Compliance is back with another exciting episode The intersection of law, compliance, and data is becoming increasingly important in the world of cross-border transactions and mergers and acquisitions.

Data analytics is a powerful tool for uncovering trends and detecting fraud – and it’s essential for compliance and internal audit roles. In this podcast episode, experts discuss how to use analytics to its fullest potential. From conducting a formal risk assessment to creating a control inventory list, to looking at suspicious payment activities, the journey of compliance monitoring is broken down and explained. Predictive analytics and artificial intelligence are also discussed as potential future developments that can be utilized. This podcast provides an insightful look into the importance of data analytics and how it can help make informed decisions.

Key Highlights

·      Data Analytics Usage

·      Compliance Monitoring Journey

·      Detecting Fraud

·      Data Analytics

·      Free Resources

 Resources:

Anselmo Guevara on LinkedIn

 Tom Fox 

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Innovation in Compliance

Innovation in Compliance – Travis Howerton on Automating Security & Compliance

In this episode, Tom welcomes back Travis Howerton and they explore the importance of NIST 800-53 Rev. 5, the latest version of the National Institute of Standards and Technology’s security guidance for organizations. With new controls to address privacy and a heightened focus on supply chain and third-party risk, this version of the NIST standard is essential for organizations to access government contracts and revenue and is increasingly important to protect organizations from cyberattacks. Automation is also becoming increasingly necessary to help organizations meet these standards, highlighting the need for continuous improvement of security measures. This episode goes in-depth on NIST 853 Rev Five, making it a must-listen for organizations looking to stay secure and compliant.

The US government is increasingly turning to automation and AI to meet its security and compliance standards. With the transition of FedRAMP from guidance to law, companies are now required to use it and meet certain cybersecurity standards to do business with the US government. NIST 800-53 Rev. 5 addresses regulatory change around privacy with GDPR and other things and includes new control families and changes to existing ones.

As the government continues to revise its standards, the need for automation is becoming increasingly important. The National Institute of Standards and Technology (NIST), a standards body within the federal government, is working with the Open Security Controls Assessment language (OSCAL) team to develop standards. NIST has interacted closely with the OSCAL team, creating an open-source repo on GitHub and building communities of interest. Additionally, NIST works with other government agencies, tool providers, and industry to develop standards.

FedRAMP provides clarity of goal for vendors and customers but is expensive and time consuming to achieve. Cybersecurity is no longer a cost center, but a requirement to do business with the US government. The Department of Defense requires companies to meet certain cybersecurity standards to do business with them. Other agencies are taking similar stances in regard to cybersecurity. Companies are now required to have a compliance program to do business with them. Cybersecurity is now seen as one of the top risks to businesses, causing legal risk, revenue loss, and embarrassment.

Key Highlights

·      NIST 800-53 Rev. Five

·      NIST and FedRAMP

·      Cybersecurity Requirements

·      Cybersecurity Regulations

·      Continuous Improvement of Standards

 Resources

 Travis Howerton on LinkedIn

RegScale

Tom Fox

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Daily Compliance News

Daily Compliance News: August 8, 2023 – The Shocked, Just Shocked Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance brings to you 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. Each day we consider four stories from the business world, compliance, ethics, risk management, leadership, or general interest for the compliance professional.

·       Largest Altice shareholder ‘shocked’ about corruption allegations. (Broadband)

·       Zoom order employees back to the office.  (NYT)

·       Former CISA head blasts new SEC disclosure rules. (FT)

·       Siemens under ABC investigation in Austria.  (Reuters)

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SBR - Authors' Podcast

SBR Authors Podcast- Larry Kasanoff- A Filmmaker’s Guide to Creative & Business Mastery

Welcome to the Sunday Book Review, the Authors Podcast! Don’t miss out on this episode of SBR-Author’s Podcast, where Tom Fox sits down with noted Hollywood producer Larry Kasanoff to discuss his upcoming book, A Touch of The Madness.

This podcast episode explores the essential creative and business concepts for anyone in the film producing business. From learning how to persuade someone to say yes and cultivate your creative empowerment, to understanding the need for risk-taking in movies and the potential of 3D movie making and globalizing animation, this episode provides insightful tips and knowledge to help filmmakers create impactful stories. By discussing these topics, the podcast episode explores the ways the creative world can use new and innovative technology to collaborate globally and create powerful stories.

Key Highlights Include

·      Producing Movies

·      Getting to Yes

·      Creative Empowerment

·      Strategic Risk Taking

·      A Touch of Madness

Resources

Larry Kasanoff

A Touch of the Madness

Tom Fox

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Blog

HR’s Key to Unveiling the True Ethical Fabric of Organizations

Compliance professionals understand the importance of fully operationalizing compliance and embedding it into the fabric of a business. How can your Human Resources (HR) function help to both create and maintain an ethical culture at your organization? It turns out in a variety of ways. Obviously significance of incentives in driving ethical behavior cannot be forsaken but there are other areas to consider such as the impact of cross-cultural differences on ethical behavior. HR can play a role in the importance of creating a speak-up culture where employees feel comfortable reporting ethical concerns without fear of retaliation.

In a world where ethics are paramount, HR professionals hold the key to creating an ethical culture within organizations. But what happens when change is pushed too quickly, compensation drives behavior, and cross-cultural differences come into play? Discover the challenges and secrets to success in this thrilling journey of HR’s quest for an ethical culture…

In the pursuit of understanding the vital role of HR in establishing an ethical culture, I stumbled upon an unexpected revelation that shook the very foundation of my beliefs. It was a twist that challenged my assumptions and left me with a burning question: Can change truly be achieved without sacrificing ethical values? As I ventured deeper into this journey, I uncovered unsettling truths about the underlying ethos of corporations and the detrimental impact of short-term targets. But what I discovered next was even more astonishing, a revelation that would forever alter my perspective on the role of HR in creating an ethical culture…

If you are feeling frustrated and overwhelmed because your efforts to create an ethical culture are being undermined by inconsistent enforcement and lack of accountability, then you are not alone! Despite implementing compliance programs and promoting ethical values, you may find that employees still engage in unethical behavior due to a lack of consequences or clear guidelines. This can lead to a sense of disillusionment and hinder the progress towards an ethical work environment.

HR significantly contributes to embedding ethical behavior within the organizational culture. By creating a conducive environment that promotes honesty and integrity, HR can foster a culture that this significantly resistant to unethical practices. It’s primarily up to HR to ensure that employees feel comfortable voicing concerns without fear of retaliation, helping to enhance the ethical culture within organizations.

The path to cultivating an ethical culture is often met with significant roadblocks such as too much rapid change, reward-driven behaviors, and cross-cultural conflicts. These elements can create an environment where unethical behavior thrives, impacting organizational growth and success. For a moral culture to strive, these challenges should be identified and effectively addressed, paving the way for a workplace that values ethical conduct.

Understanding the underlying organizational dynamics is crucial in establishing and maintaining an ethical culture. It’s not enough just to have a written code of conduct; the actual behaviors within the organization need to be assessed and aligned with these ethical guidelines. HR plays a crucial role in comprehending these dynamics, ensuring that metrics used to reward employees promote ethical conduct rather than encouraging unethical short-term success.

Have you ever heard these myths about the role of HR in creating an ethical culture? First myth: HR is solely responsible for ethical behavior. Second myth: Creating an ethical culture is too time-consuming and costly. Third myth: HR can’t effectively enforce ethical standards. But what if I told you that these myths are far from the truth? Some key points are:

  • How HR can be the key instigator in shaping an ethically driven business culture.
  • Recognizing the potential roadblocks that could obstruct the path to ethical behavior in organizations and how to overcome them.
  • Appreciate the crucial interplay between organizational dynamics and ethics.
  • Perceive the nuanced impact of incentives on ethics and how it can steer the moral compass in corporate environments.
  • Master the art of endorsing.

My journey into understanding the vital role of human resources in establishing an ethical culture within an organization started with a deep dive into the role of HR and how those roles could that shed light on a fundamental dilemma for compliance. This dilemma was not about right and wrong, but about navigating clashing interests, misaligned incentives, and conflicting cultures. I learned that pushing too much change from the top, too quickly and too frequently can warp a company’s ethical climate. This realization led me to critically analyze the compensation plans in various organizations. The stark reality that people do what they are rewarded to do underlyes ethos of many corporations. This means that short-term targets often overshadowed long-term success, leading to a detrimental impact on the ethical culture. As I delved deeper into the concept of ethical culture, I realized that the essence of this term is far more profound and complex than it seems on the surface. This is not just about formal corporate governance documents or written codes of conduct. It is about understanding and adopting your organization’s underlying culture. It is also about self-awareness, organizational awareness, and the courage to speak up. One problem is that too many leaders tended to seek advice from their like-minded peers rather than embracing diverse opinions. This convinced me about the importance of fostering a speak up culture, and most crucially, a culture devoid of retaliation. This exploration underscored the pivotal role of HR in championing ethical norms, thereby establishing a robust and effective compliance program.