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Compliance Tip of the Day

Compliance Tip of the Day: Compliance Training Design Objectives – Part 1

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In this episode, we begin our consideration of the top 10 design objectives for any compliance training program.

 

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

To check out The Compliance Handbook, 5th edition, click here.

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Podcasting for Business

Podcasting for Business – The Book: Metrics That Matter, Part 1 – Referrals, Sales Cycle, Promos, SEO and Product Creation

Welcome to Podcasting for Business – The Book, where we dive into Megan Dougherty’s transformative book, Podcasting for Business – The Book. I’m your host, Tom Fox, and in this series, we will unpack the invaluable lessons and strategies from Megan’s book, which has quickly become the definitive guide for anyone looking to leverage podcasting as a powerful business tool. Whether you’re a seasoned podcaster or just considering how to get started, this podcast will walk you through Megan’s essential insights, from choosing the right podcast blueprint for your business to mastering the metrics that matter. Join me as we explore how to create, refine, and maximize the impact of your podcast, all through the lens of one of the most comprehensive resources available today.

In this episode, Tom Megan provides a three-episode review of the essential metrics that business podcasters should track. They start with referrals, explaining how relationship-building podcasts can generate valuable business leads. They move on to sales cycle length, demonstrating how podcasts can accelerate customer engagement. They also discuss promotional opportunities, SEO benefits, and new product creation. Megan emphasizes the importance of creating content that serves both SEO and business objectives, providing real-life examples and actionable insights.

Key Highlights Include:

  • Understanding Referrals as a Metric
  • Optimizing Sales Cycle Length
  • Leveraging Promotional Opportunities
  • SEO for Podcasts
  • Creating New Products from Podcast Content

 Resources

Check out Podcasting for Business the Book

One Stone Creative

Connect with Megan on Linkedin

 Tom Fox

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Great Women in Compliance

Great Women in Compliance: Roxanne Petraeus and Susan Divers on Building a Listen Up Culture

In this episode of Great Women in Compliance, Hemma and Sarah visit with Roxanne Petraeus and Susan Frank Divers to talk about intentionally building a “Listen Up” culture. Tune in to hear the powerful origin stories of two great women in compliance who have been moved to drive significant impact in this space, from enterprising business solutions, to innovative learning and development strategies, to thoughtful approaches to measuring culture and employee sentiment as a measure of success.

Highlights include the ways in which listening builds trust, how to measure impact, not activity, how to achieve integrated risk management, how to design your employee training with employee experience and employee sentiment in mind, and despite our aspirational claims to be building a strong speak up culture, how our employees will always be the actual arbiter of our success.

You can learn more about Roxanne and Susan’s work at www.ethena.com.

Biographies:

Roxanne Petraeus is the CEO and Co-Founder of Ethena, a compliance training platform startup with intuitive and powerful admin tools that make required training easy, engaging, and effective.

Roxanne previously consulted for McKinsey, and before that, she was an officer in the US Army. She found that no matter the setting, whether consulting or in the military, there remained an opportunity to make compliance training better. She started Ethena in 2019 with Co-Founder Anne Solmssen.

Ethena enjoys incredibly positive word of mouth within the HR community, and is trusted by thousands of companies like Figma, Notion, Noom, Pinterest, and Carta to provide actionable training. And the employees love it: Ethena has a 93% positive rating, and over 2M positive reviews. Roxanne is a natural leader, and her eagerness to question and reinvent old paradigms is at the heart of Ethena’s ascendance.

Susan Frank Divers serves as an advisor to Ethena, Inc., an all-in-one compliance training platform that helps companies create more ethical and inclusive work cultures. Prior to joining Ethena, she was the director of thought leadership and best practices for LRN Corporation for seven years.

She has 30+ years’ accomplishments and experience in the ethics and compliance arena. This expertise includes building state-of-the-art compliance and training programs, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Ms. Divers served as AECOM’s Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM’s ethics and compliance program garnered six external awards in recognition of its effectiveness and Ms. Divers’ thought leadership in the ethics field. In 2011, Ms. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

#GWIC is proud to announce that it has been nominated for the WomenInPodcastAwards.  This is a people’s choice award and whether you vote for #GWIC or other nominees, we ask that you send the elevator back down by voting. Voting opens August 1, 2024, and details can be found on the #GWIC LinkedIn page at http://www.linkedin.com/groups/12156164

Resources:

Join the Great Women in Compliance community on LinkedIn here.

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Compliance Into the Weeds

Compliance into the Weeds: The BCG Declination – Key Insights for Compliance

The award winning, 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. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into the recent Department of Justice (DOJ) declination for the Boston Consulting Group (BCG).

They highlight why this case garnered significant attention and dissect the substantive actions BCG took to avoid prosecution, including firing implicated employees and forcing equity forfeiture. The duo also explores the seven factors that led to the declination, such as timely self-reporting, full cooperation, and improved compliance measures. The episode provides a comprehensive analysis of the BCG case, offering crucial takeaways for compliance officers on how to handle potential corruption issues and DOJ expectations.

Key Highlights:

  • Overview of the Boston Consulting Group Declination
  • DOJ’s Factors for Declination
  • Full Cooperation, Timely Self-Disclosure and Employee Consequences
  • Remediation Efforts and Compliance Improvements

Resources:

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

Tom 

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Daily Compliance News

Daily Compliance News: September 4, 2024 – The Don’t Ask for Something 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.

In today’s edition of Daily Compliance News:

  • Don’t ask for something like regulatory reform, as you might get it. (WSJ)
  • Former Volkswagen Chief Executive goes to trial for the emissions testing scandal. (NYT)
  • Lebanon’s former central bank head is charged with corruption. (AP)
  • How about using AI to increase profits? (FT)

For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here.

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Blog

The Bre-X Mining Scandal, Part 1: A Scandal for the Ages

Few corporate scandals are still as infamous or devastating as the Bre-X mining scandal. What began as a story of incredible wealth, fueled by the promise of one of the largest gold deposits ever discovered, unraveled into one of the biggest frauds in mining history. For compliance professionals, the Bre-X scandal is a powerful reminder of the importance of due diligence, transparency, and robust regulatory oversight. This multi-part blog post series will explore the Bre-X scandal from multiple perspectives, beginning with an introduction to what exactly transpired during this extraordinary case of corporate deceit. We will consider how and why the story was such a sensation, the legal and regulatory response, and how the scandal can be a helpful teaching tool for the compliance professional some 30 years later.

In 1993, Bre-X Minerals, a relatively unknown Canadian company, made headlines by announcing a potentially massive gold discovery in the Busang region of Indonesia. The news sparked a frenzy in the mining world and beyond, as the company claimed that the deposit could contain an estimated 200 million ounces of gold, making it one of the largest gold finds in history. This discovery was revolutionary for a small mining company like Bre-X. At the time, Indonesia was seen as an untapped resource, and the potential wealth hidden beneath the jungles of Borneo attracted investors from all corners of the globe.

The “Gold Discovery”

Bre-X’s Busang find was framed as a rare and monumental opportunity for wealth generation, not only for Bre-X itself but for the investors who flocked to the company in the wake of its announcement. The scale of the reported deposit was enough to catapult Bre-X into the ranks of major mining companies, and its executives became media darlings. The story itself was almost too good to be true—a small company led by David Walsh had stumbled upon what could potentially be the world’s most significant gold discovery deep in the remote jungles of Indonesia. The promise of life-changing returns captured investors’ attention by suggesting that Bre-X could reveal a hidden fortune.

As Bre-X revealed more data about the deposit size, the numbers became staggering. Core samples showed consistent traces of gold, and the company claimed that further exploration could reveal even larger reserves. These announcements generated excitement and helped Bre-X grow from a little-known firm to one of the most talked-about names in the mining sector. This so-called gold rush, however, would soon prove to be nothing more than a mirage.

Stock Market Surge

The effect of Bre-X’s announcement on its stock price was immediate and dramatic. The company’s market capitalization, which had been only a few million dollars before the discovery, surged to nearly $6 billion. The stock’s meteoric rise, from fifty cents in 1994 to the equivalent of $286 in 1996, turned early investors into millionaires overnight. As word of the discovery spread, institutional investors, hedge funds, and individual retail investors clamored to buy shares in the company, convinced that they were on the ground floor of the next great gold rush.

In the mid-1990s, the mining industry was no stranger to speculative investment. The allure of striking gold—literally and figuratively—often led investors to overlook the inherent risks in such ventures. In Bre-X’s case, this rush of investment capital fueled a speculative bubble, as many investors failed to ask the critical question: was the gold deposit real? Unfortunately, many ignored this question despite skyrocketing stock prices and the promise of astronomical returns. This frenzy of speculation would soon become a financial disaster as Bre-X’s claims about the Busang deposit unraveled.

The Fraud Unravels

By 1997, the once-celebrated gold discovery began to draw skepticism. The Indonesian government, eyeing a stake in the project, negotiated with Bre-X to develop the site. At this point, Bre-X brought in other mining giants, including Freeport-McMoRan, one of the most respected names in the industry, to help develop the site and extract the gold. Freeport-McMoRan’s involvement was seen as a vote of confidence in Bre-X’s project, adding further legitimacy to the Busang gold deposit.

However, this partnership would soon expose one of the most audacious frauds in corporate history. When Freeport-McMoRan sent their geologists to the Busang site to conduct due diligence, they discovered significant discrepancies in the data Bre-X had provided. The core samples, supposedly showing rich gold reserves, did not match the site’s geology. Freeport-McMoRan’s geologists began to suspect that the samples had been tampered with, casting doubt on the entire project.

Amid these mounting suspicions, a tragic and mysterious event occurred: Michael de Guzman, Bre-X’s chief geologist and one of the key figures in the company, committed suicide by jumping out of a helicopter into the Indonesian jungle. His death, just as the company was under intense scrutiny, only deepened the mystery and speculation surrounding the project. As more questions were raised about the validity of Bre-X’s claims, the truth of the massive deception finally came to light.

The Truth Comes Out

Following de Guzman’s death, investigations intensified, and what was uncovered shocked the financial and mining worlds. It was revealed that the core samples Bre-X had been providing were “salted” with gold dust—a fraudulent practice where gold is added to samples to artificially inflate their value. The entire gold deposit was fabricated. There was no significant gold in the Busang site, and Bre-X’s multi-billion-dollar claim was a scam.

This revelation was catastrophic for investors and the company itself. As soon as the news broke, Bre-X’s stock value collapsed. Thousands of investors—from institutional firms to everyday individuals who had staked their savings on Bre-X shares—lost millions, if not billions, of dollars in the process. What had once been touted as the gold find of the century turned into a symbol of corporate greed and deceit, with devastating financial consequences.

Collapse and Aftermath

In the aftermath of the scandal, Bre-X was forced into bankruptcy, and the fallout led to a broader investigation into the company’s activities. Despite the massive fraud, no one involved in the scandal was criminally convicted. David Walsh, the founder of Bre-X, maintained that he had been a victim of the fraud rather than its orchestrator. He died in 1998 before any criminal charges could be brought against him. John Felderhof, the company’s chief geologist, was acquitted of securities fraud charges in 2007. The lack of criminal accountability left many investors feeling disillusioned and betrayed by a system that had failed to protect them from such an audacious scam.

Legacy

The Bre-X mining scandal left an indelible mark on the mining industry and the financial markets. It exposed significant weaknesses in the regulatory frameworks governing mining and resource exploration, leading to calls for stricter oversight and more rigorous due diligence in mineral discoveries. For compliance professionals, the Bre-X saga is a cautionary tale about the risks of speculative investments, the need for independent verification of claims, and the devastating impact that fraudulent activities can have on industries and investors.

As we continue this series, we’ll explore the key compliance failures that prevented the Bre-X fraud and the regulatory changes that emerged in its aftermath. Compliance officers today can learn much from the Bre-X case about identifying warning signs of fraud, enforcing robust governance practices, and protecting their organizations from falling victim to similar schemes.

Join us tomorrow as we consider why the scandal was so sensational.

Resources:

The Bre-X Fraud by Donald Goold and Andrew Willis

Bre-X-The Inside Story of the World’s Biggest Mining Scam by Jennifer Wells