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Adventures in Compliance

The Memoirs of Sherlock Holmes – Silver Blaze

The world of compliance investigations can be complex and challenging, requiring investigators to navigate through a maze of information and uncover hidden truths. In the podcast episode “The Adventure of Silver Blaze” on Adventures in Compliance, host Tom Fox explores the valuable investigative lessons that can be learned from Sherlock Holmes’ approach to solving mysteries. This episode focuses on the story of Silver Blaze, where Holmes uses his attention to detail, deductive reasoning, and pattern recognition skills to solve the case.

One of the key lessons highlighted in the episode is the importance of attention to detail. Holmes emphasizes the need to observe even the smallest details, as seemingly insignificant clues can provide crucial insights. Compliance investigators can apply this lesson by paying attention to every detail, no matter how trivial it may appear. By doing so, they can uncover hidden connections and gather valuable evidence.

Contextual analysis is another important factor in Sherlock Holmes’ investigative approach. Holmes examines the circumstances surrounding the crime and seeks to understand the broader context. He considers various factors, such as the behavior of people involved, the nature of the crime scene, and the motivation of the subjects. This lesson emphasizes the significance of understanding the context and building a comprehensive understanding of any case or investigation.

Deductive reasoning is a skill that Holmes is renowned for. He draws logical conclusions based on the available evidence and eliminates improbable scenarios. Compliance investigators can learn from this approach by using logical thinking to eliminate false leads and narrow down possibilities. By applying deductive reasoning, investigators can focus their efforts on the most relevant areas and make informed decisions.

Sherlock Holmes also emphasizes the value of disguised or unexpected evidence. In the story of Silver Blaze, Holmes notices the absence of expected evidence, such as the dog not barking, and deduces that a certain action was taken. This teaches investigators to look for the presence or absence of evidence that may be disguised or unexpected, as it can provide valuable insights.

Information gathering is a critical aspect of the investigative process, and Holmes emphasizes the importance of gathering information from various sources. He interacts with different characters, collects testimonies from multiple sources, and examines forensic evidence and documents. Compliance investigators can benefit from this lesson by gathering information from diverse sources to obtain a comprehensive understanding of the situation.

Pattern recognition is another skill that Holmes excels at. He is adept at recognizing patterns and connecting seemingly unrelated pieces of information. This ability allows him to identify the truth and solve the case. Investigators should develop pattern recognition skills to identify connections and associations that may lead to crucial breakthroughs. Data analytics can also play a role in pattern recognition, helping investigators find patterns in large amounts of data.

In addition to logical reasoning, Holmes also values intuition and creativity. He is open to unconventional ideas and thinks creatively to explore all possibilities. Compliance investigators can benefit from this lesson by being open-minded and thinking outside the box. Sometimes, unconventional or imaginative approaches uncover hidden insights and provide new perspectives.

Collaboration and consultation are also important aspects of Sherlock Holmes’ investigative approach. Holmes frequently collaborates with others, such as his trusted associate Dr. Watson, to exchange ideas and gain different perspectives. Investigators and compliance professionals can benefit from seeking advice or collaborating with colleagues to enhance their problem-solving skills and uncover new insights.

In conclusion, the episode “The Adventure of Silver Blaze” on Adventures in Compliance highlights the valuable investigative lessons that can be learned from Sherlock Holmes’ approach. Attention to detail, contextual analysis, deductive reasoning, information gathering, pattern recognition, intuition, creativity, collaboration, and consultation are all key factors that impact the effectiveness of applying Sherlock Holmes’ investigative lessons in compliance investigations. By incorporating these lessons into their investigative practices, compliance investigators can improve their ability to solve complex problems and uncover hidden truths.

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Daily Compliance News

Daily Compliance News: October 9, 2023 – The When Safety Isn’t No. 1 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 in 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.

Stories we are following in today’s edition:

  • Company inaction allegedly led to 7 worker deaths.  (NYT)
  • SFO brings corruption charges. (FT)
  • Lineup of Elon Musk legal woes. (Reuters)
  • MAGA nuts aside, companies want to be inclusive. (Bloomberg)
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31 Days to More Effective Compliance Programs

One Month to More Effective Compliance Through Innovation: Day 6 – Future of Compliance Training

Where is compliance training headed? In the 2020 Update, the DOJ stated, “companies have invested in shorter, more targeted training sessions to enable employees to timely identify and raise issues to appropriate compliance, internal audit, or other risk management functions.” While this tactical solution has proven useful, I wanted to consider the broader compliance training themes that compliance professionals have learned over the past few years to gain insight into where compliance training may be headed. I sat down with Shawn Rogers, Senior Director, Global Ethics & Compliance at Stanley Black & Decker, Inc., to provide some thoughts on the veiled land of the future of compliance training.

Compliance training needs to get to the point where managers and leaders drive compliance training based on how they perceive the risks in their organizations. In other words, an awareness of risks can permeate the organization to such a degree that managers will be able to recognize when their employees need training and can call on the compliance function to provide custom training opportunities.

Three key takeaways:

  1. Business crises almost always begin with a culture failure.
  2. Focus your most detailed training on those employees who are truly high-risk.
  3. This is the “just-in-time” training model that provides training exactly when and where the employee needs the information.

For more information, check out The Compliance Handbook, 4th edition, here.

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Innovation in Compliance

2023 Global Business Ethics Survey: Part 1 – GBES: A Snapshot of the Global Workforce Ethics

The Global Business Ethics Survey (GBES) conducted by the Ethics & Compliance Initiative (ECI) provides valuable insights into workplace ethics and compliance from the perspective of employees. Tom Fox recently had the opportunity to visit with ECI CEO Pat Harned on the 2023 GBES. This survey has become a reliable benchmark for organizations to compare their workplace culture with third-party research, allowing them to identify areas for improvement and address potential risks.

Over the past 30 years of GBES research, ECI has identified and proven that certain “outcome” metrics are indicative of the well-being of workplaces from an ethics & compliance perspective. In this, the largest and latest update to the GBES body of research, employees in 42 countries around the world told us that there is reason for concern. In Part 1 of a five-part blog post series on the 2023 GBES, Tom Fox and Pat Harned provide an overview of the GBES.

Pat Harned is a seasoned compliance professional committed to fostering ethical conduct in the business sector. As the CEO of ECI, Pat has a unique perspective on the global business ethics survey: insights into workplace ethics and compliance, shaped by her 16 years of involvement with the survey. She finds the recent survey results deeply troubling, pointing out several issues, such as high levels of employee pressure to compromise standards, increased misconduct, persistent retaliation, and a low percentage of employees reporting a strong ethical culture in their workplaces. Pat underscores the significance of a robust ethics and compliance program and is confident that the survey data can offer valuable benchmarks and recommendations for organizations aiming to enhance their programs. Join Tom Fox and Pat Harned as they delve deeper into this topic in the upcoming episode of the 2023 GBES podcast.

Key Highlights:

  • Insights into Workplace Ethics and Compliance
  • The Crucial Role of Diverse Respondents
  • Alarming Workplace Ethics and Compliance Trends

Join us in Part 2, where we consider the findings of the observation of workplace misconduct.

Resources:

ECI

2023 Global Business Ethics Survey

Blog Post on the 2023 GBES, Part 1

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Blog

2023 Global Business Ethics Survey: Part 1 – Overview

The Global Business Ethics Survey (GBES) conducted by the Ethics & Compliance Initiative (ECI) provides valuable insights into workplace ethics and compliance from the perspective of employees. I recently had the opportunity to visit with ECI CEO Pat Harned on the 2023 GBES. This survey has become a reliable benchmark for organizations to compare their workplace culture with third-party research, allowing them to identify areas for improvement and address potential risks.

Over the past 30 years of GBES research, ECI has identified and proven that certain “outcome” metrics are indicative of the well-being of workplaces from an ethics & compliance perspective. In this, the largest and latest update to the GBES body of research, employees in 42 countries around the world told us that there is reason for concern. In Part 1 of a five-part blog post series on the 2023 GBES, we provide an overview of the GBES.

The 2023 GBES reveals concerning trends that highlight the need for organizations to prioritize ethics and compliance. The GBES stated:

The following are the critical measures of “the state of ethics & compliance in the workplace”:

  • Pressure in the workplace to compromise ethical standards;
  • Observations of misconduct by employees as they go about their day-to-day work;
  • The reporting of misconduct when observed;
  • Any retaliation perceived by employees after they report misconduct and
  • Strength of workplace culture from an ethics & compliance perspective.

These findings are particularly alarming, as they indicate that unless businesses change their approach to ethics and compliance, the situation is likely to worsen.

The GBES is a longitudinal cross-sectional study, meaning that it has been conducted over a long period, but the survey participants change with each iteration. This methodology ensures a diverse and representative sample, making the survey results highly reliable. By gathering input from employees, the GBES provides a comprehensive understanding of workplace culture and allows organizations to measure the impact of their ethics and compliance programs.

Pat Harned emphasized the importance of employee input in measuring the effectiveness of ethics and compliance programs. The GBES enables organizations to understand what employees are seeing and how they perceive the culture within the workplace. This information is crucial for organizations to make informed decisions and improve their ethics and compliance programs.

The GBES report offers valuable data and benchmarks for compliance professionals, regulators, and business leaders. It provides insights into key metrics that can help organizations assess the quality of their ethics and compliance programs. The report also highlights major risk areas identified by employees, allowing organizations to prioritize their efforts and address potential issues.

One of the key takeaways from the GBES is the importance of a high-quality ethics and compliance program. The report indicates that many organizations are not focusing enough on implementing effective programs that can make a difference. This insight is relevant to various stakeholders in the compliance community, including compliance professionals, regulators, and providers. The GBES report can help these stakeholders understand what a high-quality program looks like and identify areas for improvement.

The GBES report also offers suggestions for leaders to strengthen their ethical cultures and encourage more employee reporting. By understanding the factors that influence employees’ perceptions of ethics in the workplace, organizations can take proactive steps to create a positive and ethical work environment.

To access the 2023 GBES report and obtain more information about ECI, interested individuals can visit the organization’s website at www.ethics.org. The report provides a summary of the findings, while an interactive website allows users to explore the data in more detail.

Taken together, the main findings in this GBES clearly portend that businesses today face a higher risk of misconduct and loss of public trust than ever before. From the GBES:

  • When employees say that they face pressure to compromise standards, they are more likely to observe misconduct. Pressure is at an all-time high.
  • Employees are already working in environments where wrongdoing can occur. Misconduct is at an all-time high.
  • While more employees are willing to report misconduct that they observe, the likelihood that they will experience retaliation is as high as ever. Retaliation has a silencing effect on an organization, and it occurs with alarming frequency.
  • Most employees say that their workplace culture permits unethical conduct.
  • Companies are not undertaking the most important effort that can reduce their risk for future problems, namely implementing a high-quality program.

Presently, business is one of the most trusted sectors among members of the public around the world. However, all current indications point to rampant risk for misconduct to occur. Should this take place, these organizations will not only lose the trust of their employees but that of consumers and stakeholders. Unless major changes occur, public trust in business can and will be lost.

In conclusion, the Global Business Ethics Survey provides valuable insights into workplace ethics and compliance. The latest report highlights concerning trends that organizations need to address to improve their ethics and compliance programs. By utilizing the data and benchmarks provided by the GBES, compliance professionals, regulators, and business leaders can make informed decisions and work towards creating a strong ethical culture in the workplace.

To access the 2023 GBES report and obtain more information about ECI, interested individuals can visit the organization’s website at www.ethics.org. The report provides a summary of the findings, while an interactive website allows users to explore the data in more detail.

Join us in Part 2, where we consider the findings of the observation of workplace misconduct.

For more information, check out the ECI podcast series with Pat Harned discussing the GBES here.

Categories
Blog

Classic Monster Movie Month – Leadership and Ethical Lessons from Murders in Rue Morgue

It is October and one of my favorite times of the year as I get to revisit the 1930s and 1940s classic monster movies released by Universal Pictures. This year, I want to explore some of the lesser-known Universal Picture offerings. Over the next four weeks, I will be releasing a podcast and penning a blog post on it. This week, I will discuss the 1932 classic Murders in Rue Morgue, starring horror legend Bela Lugosi. The podcast appears on the fan-favorite podcast Popcorn and Compliance.

The movie version of Murders in Rue Morgue offers valuable insights on leadership and ethics. It emphasizes the importance of balance, open-mindedness, and adaptability in leadership, cautioning against blind obsession and unethical actions. The film also underscores the significance of team loyalty and the need for leaders to foster a respectful and positive team dynamic. It encourages questioning authority and promotes a culture where team members can challenge strategies and decisions.

One of the key factors that impact leadership, ethics, and accountability in the movie is the tradeoff between the pursuit of scientific advancement and the ethical boundaries that should not be crossed. While science and research are critical for human advancement, there are ethical considerations that cannot and should not be ignored. The movie highlights the dangers of obsession and the potential consequences of prioritizing personal goals over the well-being of others. Leaders must remain balanced, open-minded, and willing to change their course of action based on new information or evidence.

The film also explores ethical concerns about the exploitation of vulnerable populations. Dr. Mirakle targets women whom he believes will not be missed by society. This raises questions about the responsibility of leaders to protect and respect the rights of all individuals, regardless of their social status or vulnerability. The movie serves as a cautionary tale about the dangers of unchecked power and the potential for abuse. It prompts reflection on the difference between legality and ethics, highlighting the importance of considering the impact on others when making decisions.

Additionally, the movie touches on the issue of animal rights and cruelty. The use of Eric the gorilla in experiments and sideshows raises ethical questions about the treatment of animals and the potential consequences of mistreating them. It reminds leaders to consider the ethical implications of their actions, even if societal norms and perceptions of cruelty have changed over time.

The film also raises the question of morality versus legality. While Dr. Mirakle’s actions may not seem illegal in the setting of the movie, they are undoubtedly immoral. This highlights the difference between what is legal and what is ethical and moral. Leaders should be aware of this distinction and strive to make decisions that align with both legal requirements and ethical principles.

Accountability is another important aspect explored in the movie. Dr. Mirakle faces consequences for his unethical practices, emphasizing the idea that actions have repercussions and that individuals must be held accountable for their unethical deeds. This serves as a reminder to leaders that they are responsible for their actions and should be prepared to face the consequences of their decisions.

In conclusion, Murders in Rue Morgue provides a thought-provoking exploration of leadership, ethics, and accountability. The movie highlights the importance of balance, open-mindedness, and adaptability in leadership, as well as the need to consider the impact on others when making decisions. It serves as a cautionary tale about the dangers of unchecked power and the potential for abuse. By examining the tradeoffs involved in balancing different factors and exploring the challenges associated with different approaches, the film prompts reflection on morality, science, individual rights, and the need for accountability.

I hope you will watch (or rewatch) this great classic movie and join me on this great and fun exploration of the Universal Pictures classic monster movie oeuvre.

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Sunday Book Review

Sunday Book Review: October 8, 2023 – The Compliance Books Edition

In the Sunday Book Review, Tom Fox considers books that would interest the compliance professional, the business executive, or anyone who might be curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest Tom. In today’s edition of the Sunday Book Review, Tom reviews four top books on compliance.

1.     Governance, Risk Management & Compliance by Richard Steinberg

2.     Corruption: The New Corporate Challenge by N. Kochan and R. Goodyear

3.     Anti-Money Laundering in a Nutshell: Awareness and Compliance for Financial Personnel and Business Managers by Kevin Sullivan

4.     The Business Guide to Effective Compliance and Ethics: Why Compliance isn’t Working – and How to Fix it by Andrew Hayward & Tony Osborn

Resource

Top 10 Compliance Books by Vivek Dodd

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10 For 10

10 For 10: Top Compliance Stories For the Week Ending October 6, 2023

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings to you, the compliance professional the compliance stories you need to be aware of to end your busy week. Sit back, and in 10 minutes, hear about the stories every compliance professional should be aware of from the prior week. Every Saturday, 10 For 10 highlights the most important news, insights, and analysis for the compliance professional, all curated by the Voice of Compliance, Tom Fox. Get your weekly filling of compliance stories with 10 for 10, a podcast produced by the Compliance Podcast Network.

  • DOJ offers self-disclosure incentives in M&A. (WSJ)
  • SBF-Backdoor Man?  (NYT)
  • Matt Levine on the SEC’s busy week.   (Bloomberg)
  • EX-A&F CEO under investigation for sexually harassing men.   (BBC)
  • Elon Musk to face trial over Twitter disclosures. (Reuters)
  • Estimating Chinese corruption. (FT)
  • Albemarle settles FCPA action.   (FCPA Blog)
  • Shinhan Bank to pay $25MM for ‘compliance problems’.  (WSJ)
  • Yet another pre-taliation case. This time, DE Shaw pays $15MM. (WSJ)
  • Clear Channel settles FCPA enforcement action. (FCPA Blog)

You can check out the Daily Compliance News for four curated compliance and ethics-related stories each day here.

Connect with Tom 

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Kerrville Weekly News Roundup

Kerrville Weekly News Roundup: October 7, 2023

Welcome to the Kerrville Weekly News Roundup. Each week, veteran podcaster Tom Fox and his colleagues Andrew Gay and Gilbert Paiz get together to go over a couple of their favorite stories from the past week from Kerrville and the greater Hill Country. Sit back, enjoy a cup of morning coffee, and listen in to get a wrap-up of the Kerrville Weekly News. We each consider two of our favorite stories and talk about the upcoming weekend’s events, which we will enjoy or participate in this weekend.

In this episode, Tom, Gilbert, and Andrew discuss the following stories that caught their attention over the past week.

  • Tom discusses the award to Kerrville Treasurer Tracy Soldan for Texas Treasurer of the Year. He reviews the attempt by certain Kerrville residents to prevent Habitat for Humanity from building 40 low-cost homes in Kerrville. He shouts out to the great sports weekend of UT v. OU football, and the Astros begin the World Series title defense and the Sunday night football game of the Cowboys v. 49ers.
  • Andrew discusses Kinky Friedman headlining the Kerrville Folk Festival’s Welcome Home Festival October 12-15 and the Riverfest Annular Eclipse Festival. Andrew shouts out to the podcast The Night Sky, which features stories on Kerrville’s upcoming two eclipses.
  • Gilbert cautions about the string of car burglaries in Ingram, the sex offender check by the KPD, and shouts out to the KPD Blue Santa program. He will be headed to the Notre Dame Fall Festival this weekend.

Resources:

Tom Fox on LinkedIn

Gilbert Paiz on LinkedIn

Andrew Gay on LinkedIn

Texas Hill Country Podcast Network

The Lead

Kerrville Daily Times

Categories
31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Innovation: Day 5 – Communication to see Around Corners

The more you can operationalize compliance, the more it works to operationalize culture in your organization. It works for all levels of a company, literally from the Boardroom to the shop floor. The DOJ and SEC recognized this when they noted in their 2020 FCPA Resource Guide, “A compliance program should apply from the board room to the supply room – no one should be beyond its reach.” Yet culture can provide more than simply an ethical foundation, and it is also a part of the business foundation of an entity.

Using such an approach to communications allows a CCO to “see around corners” and can be one of the greatest strengths of a best practices compliance program. The reason is listening. Listening is a key leadership component, and there are certainly many ways to listen. You can sit in your office and wait for a call or report on the hotline, or you can go out into the field and find out what challenges employees are facing. From this, you can work with them to craft a solution that works for the company and holds to the company’s ethical and compliance values.

Using social media tools, a CCO can move towards Thomas’ next key ingredient of a successful corporate culture, which is trust. Thomas said, “I’m obsessive about the culture that we create specifically around trust, and this is an adjustment for some people when they come here. If you join our team, there’s trust by default here. That means you trust in the competence of your teammates. You trust in their intentions and what they’re saying. At some companies, the culture is that trust is earned over time, but that means if everyone in the organization says you have to earn trust, the amount of energy that actually goes into the trust-earning process is a distraction from our mission.”

Three key takeaways:

  1. A company can fail if it does not get its culture right.
  2. Using communications to “see around corners.”
  3. Trust works as a business strategy.

For more information, check out The Compliance Handbook, 4th edition, here.