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Compliance Into the Weeds

Hotline Benchmark Report


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. In this podcast Matt Kelly and Tom Fox take a deep dive into the hotline benchmark report from Navex Global which was previewed on a recent webinar Matt attended. Some of the data was quite interesting and perhaps even troubling.
Some of the highlights include:

  • Case closure times are longer this year. Why are they lengthening?
  • The five top categories of cases reported.
  • Reports via online reporting v. telephone call nearly doubled.
  • Reports of violations of business integrity violations are on the uptick.
  • The #MeToo movement is over two years old, what do the numbers reveal?

Resources
Matt Kelly blog post, Report: Hotline Cases Taking More Time

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Daily Compliance News

April 15, 2020-the (Non) Tax Day edition


In today’s edition of Daily Compliance News:

  • Are monitors hobbled? (WSJ)
  • US repatriates $300 stolen money to Malaysia. (DOJ Press Release)
  • Former Goldman exec charged with ‘egregious’ FCPA violations. (FCPA Blog)
  • Will Texas institution oil production limits? (WaPo)
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The Compliance Life

Changing Culture Through Creative Communication with Russ Berland


Russ Berland is back on this episode of The Compliance Life to share how he uses creative communication to change compliance culture.
Changing Culture at BearingPoint
Tom Fox credits Russ with being one of the first persons to come up with a compliance movie. Russ relates that the lack of an integrated culture was one of the biggest issues at BearingPoint in 2007. His goal was to build company culture, and expectations around the same. Research suggested that they should start with their training, so Russ and his team came up with the idea of a series of videos – a “mockumentary” – similar to The Office. The team gathered stories from employees, which became inspiration for the script.
The first series of videos about the fictional Agreva Group was a phenomenal success. Russ relates that the “magic for us was that because they were our own stories, the people at BearingPoint recognized them and empathized with them…” After each six minute episode, a senior official would talk about the policies that applied to the situation portrayed in the video, and what the characters should have done. Russ comments that the training was the talk of the company: people eagerly looked forward to the release of the next episode, and diagnostic surveys showed marked cultural change as a result. One of their employees even became a local celebrity from acting in the series. They subsequently created a column and a second series of videos.
Tom comments that using the employees’ stories not only made them more targeted and engaged in the series, but also allowed Russ to gather information. Their post-diagnostic surveys helped them to measure the effectiveness of the training. Russ adds that engaging the senior leadership to talk on the videos made them the mouthpiece for the culture they were trying to create, while setting the tone from the top.
Resources
Aventiv Technologies

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31 Days to More Effective Compliance Programs

The Fraud Audit


Consider how a fraud audit using data analytics can help to detect or prevent bribery and corruption where the primary sales force used by a company are China based employees defrauding their company by using false expense reports to create a pot of money to use as a slush fund to pay bribes. Here you can think back to the Eli Lilly FCPA enforcement action up to the GSK problems as examples of where employees used their expense accounts not for personal use but for greater corporate malfeasance.
This double dipping technique led to two anti-bribery compliance enforcement actions. One in the U.S. involving Eli Lily and a second in China involving the U.K. pharmaceutical entity GSK. The risk is real and by using ongoing data monitoring you might not only get ahead of the legal violation, but you would have a much more efficient business process going forward.
Three key takeaways:

  1. The typical fraud audit will get down into the weeds with data analytics.
  2. Split dollar expenses are key metric.
  3. Double-dipping can lead to larger problems.
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Daily Compliance News

April 14, 2020-the Won’t Get Fooled Again edition


In today’s edition of Daily Compliance News:

  • Businesses to workers: you’re on your own. (NYT)
  • No jail time for Alstom cooperator. (WSJ)
  • Is he or isn’t he leaving? Bob Iger’s retirement or not. (WaPo)
  • The wrong vision at Softbank (WaPo)
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Compliance and Coronavirus

Abikoff and Huneke on corruption enforcement during the Coronavirus Crisis


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 Kevin Abikoff and Mike Huneke, from Hughes, Hubbard and Reed. We discuss their recent blog post on the FCPA Blog, There is no Covid-19 defense to corruption.
Check out their blog post on the FCPA Blog, by clicking here.
This podcast is sponsored by SAI Global. To learn how you can protect your business operations and workforce during these uncertain times, visit saiglobal.com/risk for free resources, expert guidance, and industry-leading technology.

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Innovation in Compliance

Systematizing Success with Ben Wolf


This week’s guest on the Innovation In Compliance podcast is Ben Wolf, founder and CEO of Wolf’s Edge Consulting. He chats with Tom Fox about how his company helps entrepreneurs systematize their business operations to achieve their goals.

From Lawyer To Consultant
Ben describes his career path from corporate attorney to founding his own company as a “twisting and turning journey.” He relates how he was introduced to the Entrepreneurial Operating System (EOS) framework, and the success the company enjoyed as a result of implementing it. After three years, he realized that he wanted to help other organizations grow in the same way. “So I went out on my own,” he says. Today, his consulting company helps other entrepreneurs implement EOS. 
The EOS Process
Tom asks Ben to describe the EOS process and how he helps entrepreneurs use EOS to grow their business. Ben responds that a business must be able to carry out its goals in order to be successful. “It’s just critical for any business to be able to have a good structure for how to set goals and then create discipline and accountability for getting those done,” he points out. The EOS is a framework for running all aspects of a business. In particular, it aims to help strengthen the six key areas of the business: vision, people, data, process, issue solving and traction. It helps companies achieve: 

  1. Vision –  getting everybody in the organization on the same page.
  2. Traction – getting people executing on the vision with discipline and accountability. 
  3. Healthy – having a professional, functional, cohesive and functional leadership team.

Ben relates how companies can contract an EOS implementer like Wolf’s Edge, if they think it would be a good fit.
Ben’s Podcast
Tom says he was honored to be a guest on Ben’s podcast, Win Win – An Entrepreneurial Community. Ben shares two reasons why he started the podcast and why he chose its name. 
Resources
Wolf’s Edge Consulting
bwolf@wolfsedgeconsulting.com
EOSWorldwide.com

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31 Days to More Effective Compliance Programs

The Integrity Audit


Yet another way to consider using audit for continuous improvement is through the Integrity Audit. Mary Jo White in an article entitled “What I’ve Learned About White Collar Crime” provided insight into not only white-collar criminals but the integrity of companies. Her framework lays out a way for you to think through an underutilized tool for continuous improvement, the integrity audit.
When Mary Jo White or Jonathan Marks write, you need to read, digest what they have to say and implement their suggestions. The ideas that they forward are not new, revolutionary or in the least bit controversial. Yet integrity is not often considered by compliance professionals. With the Business Roundtable’s Statement of Corporate Purpose integrity has been driven to the forefront in the rasion d’etre of a corporation. Failing to have integrity at the top or down through your organization can lead to significant corporate calamity.
Three key takeaways:

  1. The Integrity Audit is an underutilized tool.
  2. Ego and arrogance at the CEO level can lead to catastrophic corporate failures.
  3. A robust report culture can demonstrate and facilitate corporate integrity.
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31 Days to More Effective Compliance Programs

The Culture Audit


What is organizational culture? Eric R. Feldman, SVP at Affiliated Monitors Inc. (AMI), has said it comprises the mission, vision and values of an organization. A similar way to consider it might be as a company’s values, visions, norms and beliefs. Whichever way you define it or look at it, corporate culture affects how groups within a company interact with each other. A key inquiry is whether the corporate incentive structure supports the articulated beliefs of a company. How does one measure or audit these articulations?
Companies must have a high-performance corporate culture for doing business ethically. One of the ways to do so is through the culture audit. It can also be a powerful tool for continuous improvement going forward. Find out what your employees are saying about your corporate mission, vision and values and most importantly remediate if those mission, vision and values are found wanting.
 Three key takeaways:

  1. What are the mission, vision and values of a company?
  2. What are the compensation and promotion incentives in the culture?
  3. Is your motto “Always be closing” or closer to “doing business ethically and in compliance”?
Categories
Daily Compliance News

April 13, 2020-the Wordsworth edition


In today’s edition of Daily Compliance News:

  • What will the English do? (FT)
  • Sometimes the least worst option is the best? (FT)
  • Why is Boeing fighting transparency? (FT)
  • How Wordsworth informs work from home. (FT)