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Principled Podcast

Principled Podcast – S9 E13 – Is Your Hotline Running Cold? How To Get Meaningful Data from Internal Reporting.

What you’ll learn on this podcast episode

Do hotlines really work? According to the 2019 Global Business Survey conducted by the Ethics and Compliance Initiative, only 6% of E&C complaints went to hotlines, compared to 51% to direct supervisors and the remainder to higher management or human resources. So why are so many E&C programs—not to mention boards of directors—relying principally on hotline data to assess company culture and compliance? In this episode of LRN’s Principled Podcast, Susan Divers talks about reimagining hotlines with Scott Sullivan, the chief integrity and compliance officer at Newmont Corporation. Listen in as Scott shares how his team reinvented Newmont’s hotline channel and reporting process to separate the wheat from the chaff and gain meaningful information.

Guest: Scott Sullivan

Headshot_Scott_S7E18

Scott Sullivan is the Chief Integrity & Compliance Officer of Newmont Corporation, the world’s leading gold company. Newmont has approximately 15,000 employees and 15,000 contractors and has 12 operating mines and 2 non-operated JVs in 9 countries. Mr. Sullivan oversees, develops, implements, and manages Newmont’s integrity and compliance program including ethics, anti-bribery, corporate investigations, and global trade compliance. Previously, Mr. Sullivan was the Chief Ethics & Compliance Officer of a global manufacturer of fluid motion and control products with approximately 17,000 employees operating in 55 countries. Mr. Sullivan has written and contributed numerous articles on compliance programs, anti-bribery/FCPA, export controls, economic sanctions, and other ethics and compliance topics to a variety of publications. Mr. Sullivan is also a frequent local, national, and international speaker, moderator, and conference organizer on compliance, anti-bribery/FCPA, export controls, and economic sanctions.

Host: Susan Divers

Headshot_Susan_Divers_S7E18_Principled_Podcast

Susan Divers is a senior advisor with LRN Corporation. In that capacity, Ms. Divers brings her 30+ years’ accomplishments and experience in the ethics and compliance area to LRN partners and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance and substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance.

Prior to joining LRN, Mrs. 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 Mrs. Divers’ thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company’s ethics and compliance program.

Mrs. Divers’ background includes more than thirty years’ experience practicing law in these areas. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative.

Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008.

She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Mrs. Divers’ most recent publication is “Balancing Best Practices and Reality in Compliance,” published by Compliance Week in February 2015. In her spare time, she mentors veteran and university students and enjoys outdoor activities.

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The Woody Report

The Woody Report: Succession, The Final Season, Episode 9 – Church and State

Co-hosts Tom Fox and Karen Woody are back as they delve deep into the final season of Succession. From the recurring theme of personal vs. business decisions to the amazing performance from Shiv, these two bring you it all! But that’s not all – learn valuable lessons about deal-making and cultural fit, and find out why the attention to detail in the clothing and accessories of the characters is so important. And if you’re looking for a great podcast recommendation, tune in to catch their thoughts on a brand-new show – who knows, you might find your next binge-worthy obsession! Don’t miss an episode of The Woody Report, where Tom and Karen bring you all the latest in pop culture, business, and more from the final season of Succession.

Tom Fox and Karen Woody are back with another captivating episode of The Woody Report. In this episode, the hosts dive into scenes from Succession, discussing the exceptional acting and impressive visuals. They highlight Roman’s heartbreaking storyline and praise the character development of Sally. The hosts analyze the reactions to Shiv’s pregnancy announcement and speculate on Logan’s dark past. They also discuss the risky political plays involving Matsson and Mencken. The breakdown of a character at a protest and the possibility of something wrong with Kendall are also analyzed. Be sure to tune in to The Woody Report for all the details on the season finale and a glimpse into what’s to come. Don’t miss out on the excellent commentary and expert analysis from Tom Fox and Karen Woody!

Highlights Include:

  • Kendall’s confrontation with ex-wife
  • Complexities of Logan’s Women Relationships
  • Logan’s Backstory and Ewen’s Eulogy
  • Analyzing Roman’s Eulogy in Succession
  • Mencken flops on Kendall
  • Tom and Shiv
  • The Implications of Roman’s Protest Outburst
  • The WAGS

Resources

Karen on LinkedIn

Karen at Washington & Lee, School of Law

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 6 – The Risk of Distributors

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in their podcast, 2 Gurus Talk Compliance, as they dive into hot compliance topics. This episode covers the potential crisis with due diligence in China, highlights from the Compliance Week 2023 National Conference, and a recent fraud case. They also discuss strategies for managing distributor risk, stakeholder management, and the need for AI regulation. With its unique insights and engaging storytelling, this podcast is a must-listen for anyone in compliance. Take advantage of the latest episode of 2 Gurus Talk Compliance, and stay ahead of the curve!

Highlights Include:

·      Philips FCPA Enforcement Action and Distributor Risk Management

·      Stakeholder Strategy for Ethical Business Practices

·      Risks of Due Diligence in China for US Companies

·      Risks of Conducting Investigations in China

·      Quantitative skills, AI regulation, and challenges

·      Tech Hearings & Messaging Compliance Reform

·      The Problems with Ephemeral Messaging and Hot Desking

·      The Myth of Informal Office Collaboration

·      IRS Scam Calls and Sanctions Compliance

 Resources 

  1. Board governance and Strategy in a Changing Economic Landscape.
  2. How to Create a Stakeholder Strategy
  3. Messaging crackdown
  4. Corporate Crime and National Security
  5. Philips pays SEC $62 million to resolve China FCPA violations
  6. U.S. Companies in China Worry Due Diligence Will End in Spy Dramas
  7. OpenAI Founder Calls for the Global Regulation of Artificial Intelligence
  8. Why Employees Hate Hot-Desking
  9. Travis County cautions of ongoing jury duty fraud calls

Connect with Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Compliance Training From the Movies

If there is one truism from the practices of law which translates to the practice of compliance, it is that your imagination only limits you. Marc Havener, founder, and CEO of Resonate Pictures, Inc., created a series of video shorts for a consulting company on compliance and ethics. Rather than the traditional legal approach of telling employees about the corporate policy on compliance, they wanted to tell a story about compliance through the art of movie-based storytelling that wove messaging into characters to tell a story.

I have urged compliance practitioners to bring more storytelling into their compliance messaging. If you put the employee in the shoes of the person they’re watching, they will remember it because they will see how it applies to their lives. Havener noted that the training experience would last “exponentially longer than if you just go over a written policy or show a PowerPoint.” He called it “expanding your classroom.” The next time they see George Clooney, they’re going to remember the training, the next time they watch that movie that you showed a clip from, they’re going to be reminded of the training, and so it becomes a great drift method of training.”

Three key takeaways:

  1. Storytelling is another form of communication.
  2. Movie clips in compliance training can provide useful touchstones that employees can relate to for compliance lessons.
  3. The Morgan Stanley declination gave credit for annual compliance reminders.
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Hidden Traffic Podcast

Compliance Resources and News with Gwen Hassan

It’s an indictment of this modern era that exploitation remains alarmingly prevalent. Indeed, the journey towards human trafficking and forced labor prevention is laden with complexities. In this episode of Hidden Traffic, host Gwen Hassan discusses current events and valuable resources to propel the fight against human trafficking. She emphasizes the interplay between corporate compliance, survivor advocacy, and global cooperation in the quest to eradicate human trafficking and forced labor from global supply chains.

Follow Money Fight Slavery is a not-for-profit consortium specializing in human trafficking prevention. During their third annual summit, the group unveiled valuable materials, including survivor-led sessions and a keynote address by a survivor turned advocate. These first-hand narratives are key in combating trafficking, Gwen points out..

 

Unseen UK has launched a petition to urge the UK government to fill the vacant Independent Antislavery Commissioner role. Gwen is concerned about the year-long vacancy in this crucial role, and urges listeners to sign the petition. Strong leadership is crucial in the prevention of human trafficking.

 

The Mekong Club is an organization that has partnered with CNN to raise awareness about human trafficking among students worldwide. This effort is encapsulated in the ‘Sweatshop Challenge’, an immersive educational experience providing students with a simulated understanding of forced labor conditions. Gwen lauds this creative approach: “Could you do a similar type of sweatshop challenge for your supply chain workers? For people that are out there in your corporate purchasing departments who are buying from foreign suppliers so they have a real personal understanding of what human trafficking does and how injurious it is…?”

 

The recently published white paper by the Mekong Club about modern slavery risks in shipping takes a deep dive into the often-overlooked logistics portion of supply chains, highlighting its susceptibility to human trafficking. 

 

Gwen elaborates on a recent US congressional hearing on the implementation of the Uyghur Forced Labor Prevention Act and its implications on the US supply chain. It hints towards an expansion of the act, potentially encompassing electric vehicle components and eliminating the inspection exemption for shipments worth less than $800. She warns listeners, “If your supply chain touches electric vehicle production or for that matter, batteries or battery production, this could be an early warning signal that there may be additional enforcement focus coming for your supply chain.”

 

Resources:

Follow Money Fight Slavery

Unseen UK

The Mekong Club | Modern Slavery in Shipping Supply Chains

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From Last to First

From Last to First: The John Aceti Story – Episode 5: Transforming Education

What is the measure of a man? What is a life well lived? I have often thought about those questions, and with John Aceti’s help, I had the opportunity to explore them through John’s amazing life. Spry and vibrant at 93, I met John after he had published his 7th book in 92. As I got to know him and his life story, I wanted him to share his amazing and inspiring journey beginning in Niagara Falls in the 1930s to his current life in the Hill Country of Texas. Overcoming a humiliating incident at age 8, John was the first in his family to go to college, served in the Air Force, became a teacher and the principal, and retired from his first career. In his second career, he and his wife traveled internationally and ended up in Kerrville, Texas, where John began another career as an author. Join me on this fascinating journey From Last to First with John Aceti.

Join host Tom Fox in this exciting podcast episode as he chats with guest John Aceti, a former principal with a wealth of educational experience. John talks about the challenges he faced as a principal in Oley, New York, and how he managed to improve the education system in the school despite the need for more structure and continuity. He also discusses his experience evaluating teachers and walking the halls of schools, sharing his belief that most teachers do a great job, but some shouldn’t be teaching. John also highlights the importance of good teaching and classroom management and his involvement in an international program to Argentina organized through the Rotary Club.

Don’t miss this episode, where John shares his insights on the joys and struggles of being an educator. Tune in to From Last to First-The John Aceti Story, hosted by Tom Fox!

 Key Highlights:

  • John’s Experience as a Principal at North Hill School
  • Revamping Education in Outdated School Districts
  • Challenges with Open School Concept
  • Unprofessional Conduct and Evaluation of a Handicapped Child
  • Reflections on Teaching and international program

Notable Quotes:

“They were about 20 or 30 years behind. Very lackadaisical about education. There was no continuity, no structure.”

I had to come up with programs that would entice them.  I came up with a few programs that included local and international programs that I brought into that school to excite the teachers.”

“She taught several things, language, compared to Japanese and English. She taught art. She taught music. She taught dressage, dressing, different kinds of clothes, and she would go to different classrooms.”

“Our job is to educate kids, not torture them.”

 Resources

John Aceti’s author’s page on Amazon

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Compliance and AI

Compliance and AI – Vinay Kumar on the Business Uses for AI in Regulated Industries

In this episode, Tom Fox interviews Vinay Kumar, the founder, and CEO of Arya.ai. Vinay discusses the importance of regulations in AI to prevent unethical use in business, including the potential dangers of superintelligence. Vinay emphasizes the need for responsible and ethical use of AI while discussing how Arya.ai simplifies the deployment of responsible and safe AI in the banking, finance, and insurance industries. Vinay also explains how a verticalized AI cloud with observability layers can provide value to the industry by ensuring transparency, auditability, monitoring, and safety of model output to protect customer and company interests.

Don’t miss this informative podcast that will enlighten you on the proper use of AI in business and the importance of regulations.

Key Highlights:

  • ML observability and founding Arya.ai
  • From Stem Research to BFSI: Pivoting AI Development
  • AI solutions for the insurance industry
  • Importance of ML observability layer
  • Challenges of Health Claims Automation
  • Ethical Concerns in AI Usage for Business

 Key Quote:

“We thought we were solving a fundamental problem, which is simplifying the information interaction problem, and that can only happen when I spend my time more effectively on the topic rather than solving these on-ground tasks.”

Resources

Vinay Kumar on LinkedIn

Arya.ai

Tom Fox

Instagram

Facebook

YouTube

Twitter

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Everything Compliance

Everything Compliance – Episode 115 – The Insider Trading (Or Not) Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. Everything Compliance has been honored by W3 as the top podcast talk show. In this episode, we have the quartet of Karen Woody, Jonathan Marks, Matt Kelly, and from across the pond, Jonathan Armstrong. We consider a veritable potpourri of issues, including the sentence given to Joe Sullivan, insider trading, the COSO Fraud Risk Management Framework, and a new report on whistleblower best practices. We conclude with our fan-fav Shout Outs and Rants section.

1. Matt Kelly looks at the joint IIA/ACFE report on Building a Best-in-Class Whistleblower Hotline. He shouts out to Newton Minow, the first government official to say television was a ‘vast wasteland.’

2. Jonathan Marks discusses his work on the COSO Framework for Fraud Risk Management. He shouts out to BlueBell Ice Cream for creating the new flavor, Dr. Pepper Float.

3. Tom Fox shouts out to Mike Shannon, who played with the St. Louis Cardinals for over 10 years, went to 3 World Series, and then had a 60-year career as an announcer with the team. He is also the only MLB player whom Tom got an autograph from.

4. Karen Woody looks at recent insider trading cases involving the crypto world and asks if crypto is not a security, who can it be insider trading. Karen shouts out to the Netflix show ‘Jury Duty.’

5. Jonathan Armstrong considers the sentence handed down to former Uber executive Joe Sullivan, wonders about the Judge’s admonition of no more leniency, and asks what it means for GDPR enforcement. He shouts out to all those workers who got London ready for the coronation.

The members of Everything Compliance are:

•       Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at JRosen@affiliatedmonitors.com

•       Karen Woody – One of the top academic experts on the SEC. Woody can be reached at kwoody@wlu.edu

•       Matt Kelly – Founder and CEO of Radical Compliance. Kelly can be reached at mkelly@radicalcompliance.com

•       Jonathan Armstrong –is our UK colleague, who is an experienced data privacy/data protection lawyer with Cordery in London. Armstrong can be reached at jonathan.armstrong@corderycompliance.com

•       Jonathan Marks is Partner, Firm Practice Leader – Global Forensic, Compliance & Integrity Services at Baker Tilly. Marks can be reached at jonathan.marks@bakertilly.com

The host and producer, ranter (and sometime panelist) of Everything Compliance is Tom Fox, the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program in Training and Communications – Measuring Compliance Training Effectiveness

Since at least 2017, the DOJ has emphasized the need to determine compliance training effectiveness. In the 2020 Update, it stated under the section entitled “Form/Content/Effectiveness of Training” the following questions, How has the company measured the effectiveness of the training? Have employees been tested on what they have learned? How has the company addressed employees who fail all or a portion of the testing? Has the company evaluated how much the training impacts employee behavior or operations?

The DOJ enshrined the importance of determining the effectiveness of your compliance program in its 2020 Evaluation. The 2020 Evaluation demonstrates that the DOJ wants to see evidence of the effectiveness of your compliance program. This is something that many CCOs and compliance professionals still need help to determine. Both the simple guidelines suggested herein, the more robust assessment, and the results provide you with a start to fulfill the precepts set out in the 2020 Evaluation, but you will eventually need to demonstrate the effectiveness of your compliance training in the future.

Three key takeaways:

  1. You must demonstrate that you have measured the effectiveness of your compliance training.
  2. The DOJ is moving into requiring a demonstration of the effectiveness of compliance training.
  3. You should be moving towards a model of demonstrating compliance training ROI to validate the full operationalization of your compliance training.
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Compliance Into the Weeds

Compliance into the Weeds: A Compliance Response on Messaging Apps

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, going into the weeds to explore a subject more fully and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!

Join Tom Fox and Matt Kelly on “Compliance into the Weeds” as they delve into the recent SEC crackdown on messaging apps and improper employee use. The hosts explore the challenges of regulating messaging app use and provide solutions emphasizing the importance of corporate culture and risk management strategies. Hear from experts like the DOJ representative who spoke at Compliance Week 2023 and a defense contractor who offers tech solutions to monitor messaging apps on employees’ phones. With GDPR and FINRA regulations to consider, the podcast presents a comprehensive plan for compliance officers that focuses on effective controls, processes, and consequences for policy infractions. Don’t miss out on this informative podcast highlighting the importance of cultivating relationships with internal audit teams, IT teams, and other control departments to ensure proper compliance measures.

 Key Highlights: 

  • Risk management of employee messaging app usage
  • Tech solution for monitoring employees’ messaging
  • Corporate Culture Approach to Compliance in Financial Firms
  • Compliance Challenges in Monitoring Employee Communications
  • Building Relationships for Effective Compliance Management

 Notable Quotes:

“Assess your risks, put a risk management strategy in place, execute that strategy, train your employees, monitor the effectiveness, and remediate as appropriate.”

“And the tech company CEO said it is in his mind, People the policies, procedures, people and processes a more culture compliance strategy could work, but you would need to convince employees.”

“If they are also violating the policy, that’s bad. And that shows you have a corporate culture problem.”

“If it’s corporate culture, how is this any different than any difficult issue we’ve seen in compliance over the past 15 years?”

Resources

Matt 

LinkedIn

Blog Post in Radical Compliance

Tom 

Instagram

Facebook

YouTube

Twitter

LinkedIn