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Compliance Tip of the Day

Compliance Tip of the Day: How A CEO Can Set The Tone at The Top with Email

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.

Today we consider how a CEO can use the power of the humble email to set the right ‘tone at the top’ for any compliance program.

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Hill Country Artists Podcast

Texas Hill Country Artists Podcast: Inside Kerr Arts and Cultural Center with Lanza Teague

Delve into the heart of the Texas Hill Country with award winning “Hill Country Artists Podcast,” which illustrates and illuminates the vibrant tapestry of art rooted in this iconic region. From the sun-drenched limestone cliffs to the serene Guadalupe River, the Hill Country has been a muse for countless artists, providing a unique backdrop for creativity to flourish. In each episode, we uncover the stories behind the area’s most captivating artworks, converse with local artists about their inspirations, and explore the fusion of Texan traditions with contemporary artistic expressions.

In this episode, Andrew Gay steps behind the mic to sit down with Lanza Teague, the Executive Director of the Kerr Arts and Cultural Center (KACC). Lanza provides an insightful background on her journey to KACC and shares the key activities and spaces at the center. They discuss three newly installed art shows and the diverse mediums and talents involved. Teague also highlights upcoming events, including the Outdoor Painters event and the annual Texas Furniture Makers Show. Listeners are invited to engage with the center by attending receptions, becoming sponsors, or even hosting visiting artists.

Key Highlights:

  • Overview of Kerr Arts and Cultural Center
  • Current Exhibits and Events
  • Upcoming Outdoor Painters Event
  • Quick Draw Event Details
  • Annual Texas Furniture Makers Show

Kerrville Arts and Culture Center

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Daily Compliance News

Daily Compliance News: September 19, 2024 – The Woj Retires 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:

  • Woj retires. (WSJ)
  • US seeks $100MM in damages in the Baltimore Bridge accident. (Al Jazeera)
  • JPMorgan appoints senior bankers to oversee junior bankers. (FT)
  • Inflation hits the costs for a ransomware attack. (Bloomberg)

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The Corruption Files

The Corruption Files: Navigating Corporate Governance: The Hutchison Whampoa Scandal

What is stranger than fiction? The stories of worldwide corruption. In this podcast series, co-hosts Tom Fox, the Voice of Compliance and Mike DeBernardis, partner at Hughes Hubbard, discuss some of the most audacious corruption cases in anti-corruption enforcement. More importantly, they will discuss the lessons learned on what your organization can do to prevent running afoul of international anti-bribery laws.

In this episode of Season 2, Tom and Mike explore a unique corporate scandal from early 2000s Hong Kong involving Hutchison Whampoa Limited.

Unlike typical cases, there were no allegations of bribery, corruption, or significant financial penalties. Instead, the scandal revolved around the complex corporate governance issues and the control wielded by billionaire Li Ka-shing. The conversation delves into the importance of robust corporate governance, particularly in safeguarding the interests of minority shareholders in companies dominated by powerful individuals or families.

Tom and Mike highlight the expanding role of compliance professionals in overseeing corporate governance, especially with the rise of Environmental, Social, and Governance (ESG) criteria. They discuss the importance of board independence, the need for effective internal controls, and how compliance professionals can aid in board training. With compelling examples, such as the interlock of directors in the energy sector and the Bluebell Ice Cream scandal, the episode provides a thorough insight into how corporate governance issues can impact reputations and operational integrity.

Key Highlights:

  • Corporate Governance and Compliance
  • The Role of Boards in Risk Management
  • Compliance Professionals and Corporate Governance
  • Importance of Independent Board Members
  • Internal Controls and Compliance
  • Training Boards for Effective Governance

 Resources:

Mike DeBernardis on LinkedIn

HughesHubbardReed

Tom Fox

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Pawtastic Friends - The Paw Talk

Pawtastic Friends: The Paw Talk – Hercules, Angelina and Prince

Welcome to Pawtastic Friends-The Paw Talk. In this podcast, host Tom Fox will visit with Michael and Melissa Novelli, co-founders of Pawtastic Friends, as well as those who work with them at Pawtastic Friends. Michael and Melissa are dedicated to helping shelter and rescue dogs in the Las Vegas area become more adaptable, through enrichment training and activities such as yoga and aquatics training, as well as obedience and agility. This podcast is sure to tug on your heartstrings; just listen to how sweet this one dog is! Tune in now to hear more from Michael and Melissa Novelli as they discuss their passion for helping pups in need. Get ready for an exciting episode of Pawtastic Friends – The Paw Talk!

In this episode, we feature Hercules, Angelina and Prince.

We also introduce the Fostering Initiative Project, a pioneering effort designed to engage the public in fostering homeless animals. This project organizes monthly foster fairs and offers various fostering opportunities, aiming to save animals’ lives by finding temporary and eventually permanent homes with loving families. Tom highlights the importance of fostering for providing dogs with love, structure, and consistency, benefiting both the animals and rescues by helping them understand the dogs better for future adoptions. Michael echoes this sentiment, emphasizing that fostering offers a much better environment compared to boarding and appreciates the initiative’s growth through events that encourage public participation. Melissa underscores the project’s significance in addressing the crisis of homeless animals, promoting various types of fostering, and organizing educational fairs to boost community involvement and support. Together, their perspectives highlight fostering as a transformative solution for both animals and the community.

Quotes:

“Well, we know where the talker in the group is.” – Michael Novelli

“Fosters are incredible because fosters give the dog love, they give the dog structure, they give the dog consistency as it would be in a forever home.” – Melissa Novelli

“Is the dog the best fit? Is the family the best fit? And that’s with adoption or fostering. You know, we want to set everybody up for success.” – Melissa Novelli

Resources:

Pawtastic Friends

Donate to Pawtastic Friends

Pawtastic Friends on Instagram

Pawtastic Friends on Facebook

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Blog

Tone at the Top Week: Part 4 – CCOs Using Team Meetings to Further Compliance

We continue our blog post series on how CEOs and top senior executives can demonstrate the ubiquitous Tone at the Top. Setting the tone of doing business ethically and in compliance is one of the most critical responsibilities for CEOs and senior executives. While large-scale communications such as town halls and corporate-wide emails certainly play an essential role, there is one venue where the tone can be effectively set in a more actionable and intimate way: team meetings.

Team meetings, often focused on operational topics, provide a unique opportunity for leaders to engage directly with their teams on compliance matters. These smaller, more focused settings allow meaningful discussions about ethical behavior, compliance risks, and policy adherence. By strategically incorporating compliance into team meetings, executives can ensure that ethical considerations are baked into daily operations and decision-making processes. This post will explore how CEOs and senior leaders can leverage team meetings to reinforce compliance and establish the right tone at the top.

  • Make Compliance a Standing Agenda Item in Leadership Team Meetings

Leadership team meetings often involve high-level business strategy, performance metrics, and operational objectives. However, these meetings are also an opportunity to highlight the importance of compliance. Senior executives and department heads are role models within the organization. When they treat compliance as a priority in their discussions, it signals to their teams that ethical behavior and adherence to the law are non-negotiable elements of the company’s operations.

How to Implement

  • Ensure that compliance is a standing agenda item in leadership team meetings. This could include updates on compliance program initiatives, discussions of recent compliance risks, or analysis of how regulatory changes might impact the business.
  • Encourage leaders to cascade these compliance messages to their direct reports, ensuring the organization is aligned at all levels.
  • Use these meetings to identify areas where compliance could be strengthened within each department and provide executives with the necessary resources to address these gaps.

By making compliance a regular part of leadership conversations, you normalize it as part of the company’s strategic considerations.

  • Lead by Example in Your Own Meetings

One of the most powerful ways to set the tone at the top is to demonstrate your commitment to compliance in team meetings. Senior executives must embed compliance into every conversation about business decisions, strategies, and performance metrics.

This is crucial because people tend to imitate their leaders’ behavior. When executives consistently incorporate compliance considerations into discussions about business operations, it becomes clear that ethical behavior is not a separate initiative but part of how the company functions.

How to Implement

  • When reviewing business strategies, ask questions about managing compliance risks. For example, if a new product is being launched, inquire about the regulatory requirements and whether the company is meeting them.
  • During performance reviews, assess how managers and employees adhere to the company’s compliance policies. Reward ethical behavior, not just financial or operational results.
  • Be transparent about the compliance challenges the company may face and how you expect the team to address them.

Leading by example shows that compliance isn’t just the responsibility of the legal or compliance department—it’s everyone’s responsibility.

  • Conduct Regular Compliance Check-ins with Department Heads

CEOs and senior executives should meet regularly with department heads or team leaders to discuss how compliance is integrated into their teams’ day-to-day operations. These check-ins provide an opportunity to evaluate how well the company’s compliance program functions. Compliance risks vary by department, so it’s important to ensure that leaders at every level actively manage them. Regular check-ins provide insight into how compliance initiatives are being implemented and whether additional support is needed.

How to Implement

  • Schedule monthly or quarterly meetings with department heads to discuss compliance. Topics should include how well the department is adhering to company policies, any challenges they face in meeting compliance requirements, and potential risks.
  • Ask for updates on compliance training within each department—are employees attending, and is the training effective? Offer resources and assistance if certain areas need more focus.
  • Use these check-ins to identify potential areas of non-compliance or emerging risks and take steps to address them before they escalate.

Regular compliance check-ins create accountability among department leaders and ensure that compliance is continuously monitored across the organization.

  • Reinforce Compliance Training and Policies in Team Meetings

One of the most practical ways to integrate compliance into team meetings is by reinforcing the importance of compliance training and company policies. While formal training sessions are crucial, ongoing reminders help ensure compliance stays at the top of employees’ minds. Compliance is an ongoing process, not a one-time event. Reminding employees about training sessions, policy updates, and regulatory changes helps keep the compliance program fresh and relevant.

How to Implement

  • Use team meetings to remind employees of upcoming compliance training sessions. Personalize your message by explaining how these training sessions directly relate to their roles and the risks they may encounter.
  • Discuss any recent updates to company policies or new regulations affecting the business. Ensure that everyone understands the implications of these changes and how they should adjust their behavior accordingly.
  • Endorse compliance training by sharing examples of how it has helped the company avoid risks or improve operations. Your endorsement will increase employee engagement with these programs.

Reinforcing training and policies regularly helps ensure that employees remain aware of their compliance obligations.

  • Open the Floor for Compliance-Related Concerns and Questions

The final and arguably most important way to set the right tone at the top is by encouraging open dialogue about compliance. Team meetings offer an opportunity to create a safe space where employees feel comfortable raising compliance concerns or asking questions. Always remember that part of a Speak Up culture is listening.

This point is of the utmost significance. When employees are afraid to speak up about compliance issues, small problems can quickly escalate into major risks. By fostering a culture of openness, you encourage employees to address potential problems proactively before they become serious.

How to Implement

  • At the end of each meeting, allocate time for employees to ask questions or raise concerns related to compliance. Make it clear that you take these issues seriously and that there will be no retaliation for speaking up.
  • Encourage managers to follow up on any concerns raised and ensure that they are addressed promptly. If necessary, escalate issues to the compliance team for further investigation.
  • Lead by example by actively engaging with any compliance concerns during the meeting. Show that you are approachable and willing to help resolve compliance issues.

Creating an environment where employees feel empowered to speak up reduces the likelihood of compliance breaches and strengthens the company’s overall integrity.

The Power of Team Meetings in Compliance Leadership

Establishing the right tone at the top for a best practices compliance program is not a one-time event; it requires ongoing engagement and consistent messaging. Often viewed as operational, team meetings offer a critical venue for CEOs and senior executives to reinforce their commitment to compliance in an actionable, intimate setting.

By making compliance a standing agenda item, leading by example in your meetings, conducting regular check-ins, reinforcing training, and opening the floor for concerns, senior leaders can build a culture where compliance is not just an expectation but a fundamental part of how the company operates.

Ultimately, this consistent, hands-on approach builds trust, fosters accountability, maintains compliance, and becomes an organizational competitive advantage.

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Compliance Tip of the Day

Compliance Tip of the Day: How a CEO Can Set The ‘Tone at The Top’ – Part 3

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.

Today, we conclude our look at how a CEO can lead with tone at the top for any compliance program.

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Daily Compliance News

Daily Compliance News: September 18, 2024 – The Fireworks Coming 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:

  • Fireworks are coming in a bribery case against a retired Admiral. (WaPo)
  • Venezuela asks to delay CITGO sales. (Reuter)
  • First Flint, now Wolfsburg? (FT)
  • Astra-Zeneca employees arrested in China. (Bloomberg)

 

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Compliance Into the Weeds

Compliance into the Weeds: Everything Old is New Again – The John Deere FCPA Enforcement Action

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 Securities and Exchange Commission FCPA enforcement action involving John Deere.

The case centers on a $10 million civil penalty imposed by the SEC for bribery activities in the Thailand office of a newly acquired subsidiary, Wirtgen Group. This transgression spanned from 2017 to 2020, and despite having a code of business conduct, Wirtgen employees flouted rules by falsifying expenses, entertaining government officials at massage parlors, and engaging in a luxury sightseeing tour under the guise of a factory visit.

A critical issue was John Deere’s delayed integration of Wirtgen into its compliance program, leading to internal control lapses and obvious red flags in expense reports. Although Deere has since taken significant remedial actions, including firing culpable employees and enhancing its compliance and internal audit programs, the situation underscores persistent compliance challenges even for large, sophisticated firms. This episode serves as a reminder of the essential compliance lessons from past decades that firms must steadfastly adhere to.

Key Highlights:

  • Details of the Bribery Scheme
  • Internal Control Violations
  • Pre- and Post-Acquisition Due Diligence Issues
  • Remedial Steps and Improvements
  • Root Cause Analysis and Lessons Learned

Resources:

Matt in Radical Compliance

Tom

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LinkedIn

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Great Women in Compliance

Great Women in Compliance: Karen Woody on The Voice of Victims in Negotiated Plea Agreements

The recent Boeing plea agreement has led to many discussions about the role of victims in negotiated settlements, and today we have one of the top academic experts on the SEC and financial securities regulation, Karen Woody.  Karen is an associate professor at Washington & Lee School of Law. Karen and Lisa discuss why the Boeing case is a good example of who the victims are because the victims suffered a tragedy.  However, many other white-collar cases (we hope) are not as clear, especially in the FCPA bribery context, and what avenues of relief that others have, particularly in the international context.

Lisa and Karen also follow on the prior episode’s discussion of internal controls, particularly in light of the Solarwinds case. They talk about whether internal controls are the appropriate way for the SEC to pursue certain claims, such as cybersecurity or in a bribery case, and whether they should be limited to accounting provisions and whether other controls would be more appropriate, and if they don’t exist, should they?

Karen also shares her journey into academia and gives some practical tips for those who are interested in teaching and how to be resilient when one hits roadblocks. #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.