Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. I take things a different direction today, as I post a cross-podcast by Alyson Van Hooser. She is a thought leader around Millennials and Gen Z. In this episode, she discusses the quarantine effects of COVID 19 on Gen Z.
If you’re looking for tangible action steps and refreshing insights to help ignite the power of your own leadership journey, sign up for Alyson’s weekly leadership blog HERE. If your business would benefit from higher-performing leaders who better understand their diverse, check out more information about the comprehensive leadership development training provided by Alyson HERE. If you want to reach out to Alyson directly, email her alyson@vanhooser.com. Share and tag Alyson on social media– @AlysonVanHooser.
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In today’s edition of Daily Compliance News:
- Alexion to pay $25MM for FCPA violations. (WSJ)
- Herbal Life reserves $123MM for FCPA violations. (FCPA Blog)
- EU wide AML body? (Reuters)
- Dracula applauds as Indonesian law maker jailed over bribes for import of garlic. (Jakara Post)
We have been getting accountability all wrong in the compliance profession. It’s not a set of tasks – it’s a way of thinking and it has to come from the heart as well as the head. On Accountability: The Heart of Compliance Tom Fox and Sam Silverstein dig into what accountability means to the corporate compliance function and business organizations and most significantly, how to make it an integral part of your culture. In this episode Sam and I, talk about why accountability is good for the bottom line and why it will work for your organization. Some of the highlights include:
- Accountability is even more during the time of Coronavirus.
- Accountability is a way of thinking and a way of acting.
- How does accountability help drive greater ROI and the bottom line.
For more information on Sam Silverstein and his work on accountability, click here.
In addition to not following President Trump’s advice to have having bleach for breakfast and UV light for lunch, we now add Blue Bell Ice Cream to the “No-Eat” list for their criminal behavior leading to three deaths from listeria. Sad for this loss but determined to persevere, self-distancing Tom and Jay are back to consider some of the top compliance articles and stories which caught their collective eye this week.
- Blue Bell Ice Cream pleads guilty to two misdemeanor counts of distributing adulterated ice cream products. Mike Volkov blogs and podcasts about it in on Corruption Crime and Compliance. Tom intones on the FCPA Compliance and Ethics Blog. Jon Rausch on Dipping Through Geometries. More from Tom on the former CEO and Chairman of the Board criminally indicted for lying about it. Tom further reports with a two-part blog on the Board’s corporate governance failures, Part-1 COIs and Part 2-Caremark failures.
- Rough sailing ahead for CCOs in cruise line industry. Matt Kelly weighs in on Radical Compliance. Tom and Matt take a deep dive in this week’s Compliance into the Weeds
- The SEC responds to criticism and ramps up its whistleblower awards. Dave Michaels reports in the WSJ.
- Moro resigns in Brazil, setting off a political crisis. Jessie Bullock In the Global Anti-corruption Blog.
- NY DFS files action against opioid mfg for insurance fraud. Lawyers from Paul Weiss in NYU’s Compliance and Enforcement blog.
- Lost in a sea of regulations? Kristy Grant-Hart explains how to navigate it in a guest post on Ethics and Compliance Matters.
- Another Caremark case survives in Delaware. Kevin LaCroix in the D&O Diary.
- Did US gov purchase from sanctioned entity? Geert Vermuelean in Risk and Compliance Platform Europe.
- Should it be decision-making instead of risk management? Norman Marks in Governance, Risk Management and Audit.
- Interested in moving to the CCO chair? Check in on this month’s edition of The Compliance Life where Tom visits with Ellen Hunt, CCO at AARP. In this Part 1, Hunt discusses the start of your journey. New episodes appear each Tuesday in May at 1 PM CST. The Compliance Life is now available on iTunes.
- Tom has a wide ranging discussion with Nick Gallow on Compliance Lines’ new podcast, The Ethics Experts. Available on the Complaince Podcast Network.
- On Compliance and Coronavirus this week: James Gellert on financial health of 3rd parties as a key DD inquiry; Ben Wolf on the new normal of doing business after Covid-19; Fry Wernick on ephemeral messaging and video conferencing under the FCPA. Compliance and Coronavirus in sponsored by SAI Global.
- On the Compliance Podcast Network, Tom explores May’s topic of written standards; on 31 Days to a More Effective Compliance Program. This week’s offerings: Monday-Clearly articulated written standards; Tuesday-the Code of Conduct; Wednesday-Code of Conduct: Structure and Format; Thursday– Design of your Code of Conduct; Friday– Training on your Code of Conduct. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
Stop by for a quick visit on CCPA and GDPR and how to register for your future EU travel, when we can hopefully travel again.
Next is the design of your Code of Conduct. Through attention to detail in the design process, you should be able to come out at the end with a code which will help you to more fully operationalize your compliance program. You must begin with a determination of what you are trying to accomplish. It does not serve you to try and list every compliance risk you might think your company may encounter. You should determine the values you want to communicate, what the expectations are for employees and how to call the hotline. Under such an approach, a Code of Conduct can be the jumping off point for training on the issues stated in it. It can also form the hub of the wheel for other policies and procedures and written standards you want to communicate to relevant stakeholders.
You should also consider how you are going to distribute your code to your employees and stakeholders. If it is through an Adobe .pdf document, which is accessible for most stakeholders across an organization or via another method. If a significant part of your workforce does not have access to computers, online production only will not work as the primary distribution platform.
Three key takeaways:
- Get your business folks involved in your Code of Conduct from the outset.
- Your ethical values should be integrated into and integral to your Code of Conduct.
- How have you operationalized your Code of Conduct?
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by Fry Wernick, a partner at Vinson & Elkins. We discuss how the DOJ’s policy on ephemeral messaging will come into play during the time of the Coronavirus health crisis and what compliance officers need to do to capture and store communications.
Categories
CCTV and Data Privacy
In this episode I visit with Jonathan Armstrong are back to discuss issues relating to data privacy, data protection and GDPR. Today, we consider the intersection of Closed Circuit Television (CCTV) and data privacy. Some of the highlights are:
- CCTV is ubiquitous in the UK. Why is a DPIA so critical in GDPR compliance around this issue?
- What about the safety implications for CCTV?
- What about Subject Access Requests?
- Transparency is critical. This means full notice to all employees.
- What should be your retention policy?
Check out the Cordery Compliance, client alert on the CCTV and data privacy, click here. For more information on Cordery Compliance, go their website here. Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.
Richard Lummis and I are back with more business leadership lessons. In this episode of 12 O’Clock High, a podcast on business leadership, we take a look at leadership lessons from the Marcus Aurelius who was Roman Emperor from 161 to 180. He was the last of the rulers known as the Five Good Emperors and the last emperor of the Pax Romana, an age of relative peace and stability for the Roman Empire. He was a Stoic philosopher and it is from that tradition we present his leadership lessons applicable to today’s business executive.
Highlights of this podcast include:
- Background of Marcus Aurelius.
- Philosophical learnings of Marcus Aurelius.
- What led to writing of Mediations?
- Lessons from Meditations.
- Business lessons.
- Leadership lessons. Why did they participate? Is there one right reason?
- Rules for life.
- Final thoughts on leadership lessons.
Resources
10 Rules for Being an Exceptional Leader
Ten Rules for Life
Why business leaders look to stoicism
Mediations
