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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 3 – Compliance and Corporate Principles in Today’s World

For corporations, navigating the political landscape has become an increasingly difficult task. While being admonished to ‘stay in their lane’ by some, businesses are just like their stakeholders, impacted by the ever-changing political miasma. When this new reality is coupled with the new levels of transparency in companies, which are only amplified by social media, a company can be embroiled in public controversies with one or more stakeholder groups. As these situations occur, CCOs and compliance professionals will be called upon to help companies navigate this fraught process.

How can compliance help a company navigate through all of this? To make and implement the best strategic choices in this environment, leaders will have to

  1. develop principles to guide strategic choices,
  2. address ethical issues early on,
  3. consistently communicate and implement their choices,
  4. engage beyond the industry to shape the context and
  5. learn from mistakes to make better choices in the future.

This is a process that the corporate compliance function can facilitate. If you work through these steps, you should be able to prepare your organization for the next major shock.

 Three key takeaways:

1. Why a company can no longer simply ‘stay in its lane’.

2. Compliance should lead the way to develop robust principles to guide cultural choices.

3. Even in culture, continuous improvement is a mandate.

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GalloCast

Gallocast – Episode 12: Halloween and Day of the Dead

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the Gallocast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is an excellent insight on compliance brought to you by the co-CEOs of ComplianceLine. Fun, witty, and insightful with a dash of the two brothers throughout. It is like listening to the Brothers Gallo talk about compliance at the Sunday dinner table. Hosted by Tom Fox, the Voice of Compliance.

Halloween and Day of the Dead are just past us as the Brothers Gallo return for another Gallocast. Nick Gallo, in discussing SBF and FTX, emphasizes the importance of legal guidance and accountability in navigating complex ethical issues. He believes in the power of effective communication and strategic leadership in advocating for corporate ethics and compliance. On the other hand, Gio Gallo, with his focus on storytelling and advocacy, stresses the significance of securing budget allocation towards compliance and ethics from the executive suite. He believes a cultural shift within the organization involving a diverse group of individuals is crucial in addressing compliance and ethics challenges. Join Tom Fox, Nick Gallo, and Gio Gallo as they delve deeper into these topics in this episode of the GalloCast podcast.

Key Highlights:

  • SBF and Advice of Counsel defense. Where does the leadership buck stop?
  • RTW or WFH. How should an employer(s) approach this topic?
  • DS Disco- Why would 25% of the workforce write a letter to BOD asking them to fix corporate culture?
  • At what point should a start-up build out its internal controls? How about a compliance program?
  • How transparent should your whistleblowing process be with a reporter?
  • UM, the football program, is being investigated for electronic sign stealing.
  • What happens if a whistleblower allegation is made in bad faith?

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

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A Yank at Oxford

A Yank at Oxford – Episode 8 – A Group Looks Back

Tune in every quarter to learn how David Simon, a 53-year-old lawyer from the US, navigates the ancient world of Oxford University in pursuit of an MBA. David is a Partner at the white shoe law firm Foley and Lardner and has dedicated his career to white-collar compliance with a heavy international focus. “My practice touches a lot on some of the sanctions and international trade issues that typically come up on international matters,” he says. In A Yank in Oxford, David and host Tom Fox will discuss what inspired his decision to pursue an Executive MBA and his hopes for where the journey may lead.

In this episode, David brings five colleagues from the Oxford Executive MBA program to reflect on their time together over the past couple of years, what they learned, and how they may use it all going forward. You will thoroughly enjoy this episode of A Yank in Oxford.

Participants:

Knox Mcilwain

Joe Odachowski

Tariq Zufar

Juan David Velasco Kerguelen

Key Highlights:

  • Transformative Learning and Global Networking in Oxford
  • Balancing Work, Family, and Academic Life
  • Improving Coordination in Human Rights Advocacy
  • Diverse Brazilian Cultures and Global Perspectives
  • Addressing Pakistan’s Water Crisis Through Sustainable Solutions
  • Exploring Career Shifts and Expanding Perspectives
  • The Impact of the EMBA Program on Careers

Resources:

David Simon at Foley and Lardner

 Tom Fox

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Because That's What Heroes Do

Because That’s What Heroes Do: Loki, Season 2, Episode 4 – Heart of the TVA

Get ready for an exciting new season of Because That’s What Heroes Do. In it, Tom and Megan review Loki, Season 2. In this episode, we discuss Episode 4-the Heart of the TVA, taking a deep dive into this time-bending episode.

The Marvel series “Loki” has captivated audiences with its exploration of the Time Variance Authority (TVA) and the intricate character development of Loki and Sylvie. In this context, Tom Fox and Megan Dougherty offer their unique perspectives on the series. Tom, intrigued by the concept of time variance authority and the character development of Loki, expresses his love for the paradoxes and time loop quandaries presented in the show. His interest is deeply rooted in the complexities of time travel and character development in the Marvel series.

On the other hand, Megan discusses Loki’s ability to enchant and his conversation with Sylvie about playing God and making decisions regarding the TVA and the timelines. She finds Loki’s statement that “we are god” and someone has to make the decision to be one of her favorite moments. Like Tom, Megan also seems to have a keen interest in the complexities of time variance authority and Loki’s character development. Join Tom Fox and Megan Dougherty on this episode of the Because That’s What Heroes Do podcast as they delve deeper into these fascinating aspects of the Marvel series “Loki”. 

Highlights:

  • Time-Bending Intrigue in “Loki”
  • Loki’s Paradoxical Duality
  • The Intriguing Blue Glow Mystery

Resources:

Megan Dougherty

LinkedIn

One Stone Creative

Twitter

Tom

Instagram

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LinkedIn

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Daily Compliance News

Daily Compliance News: November 3, 2023 – The No Material Impact 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 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.

  • Altice USA says the corruption probe will have ‘no material impact’ on business. (Bloomberg)
  • Costco is in trouble for stocking products produced by forced labor. (WSJ)
  • The FDIC is probing former First Republic officers. (Reuters)
  • Big 10 coaches are livid over UM football cheating. (ESPN)
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Blog

Leadership Lessons from the President of the Republic of Texas – Anson Jones: Education for the Future

The Republic of Texas holds a unique place in American history as a short-lived independent nation. In this special four-part blog post series, I will be diving into the intriguing world of the presidents of the Republic of Texas, shedding light on their leadership styles, political tensions, and the challenges they faced. This blog post focuses on one of the lesser-known presidents, Anson Jones, the final President of the Republic of Texas.

Anson Jones played a crucial role in annexing Texas to the United States. Despite facing opposition, Jones was determined to maintain stability in the republic and ensure its successful integration into the American system. His presidency coincided with significant immigration to Texas, with people from Germany, Alsace, and the Deep South bringing diverse perspectives and ideas that challenged existing norms.

Education has always been a priority in Texas, with the belief that an educated population is vital for the republic’s success. While state control over public education took time, universities were set up, and the Texas Education Agency became fully invested in shaping education delivery by 1949.

Jones’s dedication to continuing Sam Houston’s work in promoting the annexation of Texas was a defining characteristic of his presidency. Despite facing opposition and conspiracy theories surrounding Houston’s departure from politics, Jones kept his hand on the tiller and steered the republic towards annexation. His persistence and dedication to the cause were instrumental in Texas officially becoming part of the United States in January 1846.

Different ideas of what Texas ought to be were the driving forces behind its annexation. Some believed in embracing the American vision and becoming part of the American machine, while others saw Texas as an opportunity to establish their own unique identity. The presidents of the Republic of Texas, including Jones, expressed their understanding of the American experience and put different emphases on their visions for Texas.

Education played a significant role in shaping the future of Texas. Mirabeau B. Lamar, a previous president, laid the foundations for the state’s school system, and Jones himself endowed a university. The emphasis on education stems from the belief that knowledge is power and that an educated population is better equipped to uphold the principles of the republic. However, implementing a comprehensive education system proved challenging.

It wasn’t until the mid-20th century that Texas saw significant progress in state control over public education. Universities such as the University of Texas and Texas A&M were established, and the Texas Education Agency took on the responsibility of shaping education delivery across the state. However, even then, there were still areas where access to education remained limited, particularly in rural areas.

Anson Jones served as the fourth and final President of the Republic of Texas from 1844 to 1846. His leadership during this period provided several valuable leadership lessons.

  1. Diplomacy and Negotiation: Jones was a skilled diplomat who worked to secure the annexation of Texas by the United States. His diplomatic efforts highlight the importance of negotiation and building strong relationships to achieve political goals.
  2. Persistence and Patience: Jones faced numerous challenges and setbacks in his pursuit of annexation, but he remained persistent in his efforts. Compliance leaders should be patient and willing to persevere despite obstacles and setbacks.
  3. Adaptation to Changing Circumstances: As the political landscape evolved with the U.S. presidential election of 1844, Jones adapted to the changing circumstances to align Texas with the interests of the United States. Effective compliance leaders should be flexible and able to adjust their strategies as situations and corporate risks change.
  4. Strategic Timing: Jones carefully timed the submission of Texas’s annexation request to the United States, aligning it with favorable political conditions. Timing is critical in leadership, and compliance leaders should be strategic in choosing when to act on important initiatives.
  5. Vision and Advocacy: Jones strongly advocated for Texas annexation and had a clear vision for its future as part of the United States. Effective compliance leaders articulate their vision and passionately advocate for their goals to inspire and rally support.
  6. Collaboration and Alliances: Jones worked closely with influential political figures, including President James K. Polk, to advance Texas’s interests. Building alliances and collaborating with key stakeholders is not simply essential but mandatory for compliance leaders to achieve their objectives.
  7. Foresight and Planning: Jones’s leadership included careful planning and strategic thinking. CCOs and compliance leaders should anticipate challenges and develop plans to address them effectively.
  8. Ethical Leadership: Jones upheld ethical principles and maintained a commitment to democratic processes throughout his presidency. Compliance leaders should demonstrate ethical behavior and adhere to their values, even in the face of business pressures to approve unwarranted risks or other nefarious activity.
  9. Decision-Making Under Pressure: The annexation process placed immense pressure on Jones, but he made critical decisions thoughtfully and with a focus on the best interests of Texas. Compliance leaders must be able to make difficult decisions under pressure.
  10. Legacy and Transition: Jones played a pivotal role in Texas’s transition from a republic to a state within the United States. Compliance leaders do not often consider their legacy and the impact of their decisions on the future of their organizations, but they should do so.

Anson Jones’s leadership during his term as President of the Republic of Texas offers lessons in diplomacy, persistence, strategic timing, vision, collaboration, foresight, ethical leadership, and decision-making under pressure. His efforts ultimately led to the annexation of Texas by the United States, shaping the state’s history and its place in the Union.

Education development in Texas highlights the importance of execution and the challenges of implementing educational policies. While the presidents of the Republic of Texas laid the foundations and set the cornerstones, it took several decades for education to gain momentum and for state control to be fully established.

In conclusion, Anson Jones’ presidency and the education development in Texas were intertwined with annexing Texas to the United States. Jones played a crucial role in steering the republic toward annexation, and education remained a priority throughout this period. The challenges faced in implementing a comprehensive education system highlight the importance of considering the impact and tradeoffs involved in decision-making. Education continues to be a vital aspect of Texas’ identity and plays a significant role in shaping the state’s future.