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FCPA Compliance Report

FCPA Compliance Report – Adrienne Bellehumeur on The 24-Hour Rule: Mastering Dynamic Documentation

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Join Tom Fox, the host of FCPA Compliance Report, as he speaks with Adrienne Bellehumeur, a consultant specializing in business analysis, audit, internal control programs, and effective documentation. In this episode of the FCPA Compliance Report, they discuss the secrets to smarter organizations and the importance of the 24-hour rule for documenting and retaining information. Adrienne, author of “The 24-Hour Rule,” provides practical and comprehensive techniques for dynamic documentation and pushes individuals and organizations forward through a six-step process. The discussion also covers the challenges of managing information in communication tools like Slack and WhatsApp and the need for clear repositories for future value and legal purposes. Take advantage of this informative episode and get your hands on Adrienne’s book now!

Key Highlights:

· The 24-Hour Rule: Importance of Documentation

· Dynamic documentation for managers and directors

· Mastering Successful Documentation: The Six Steps

· Effective Documentation and Data Governance

· Effective Information Management in Communication Tools

Notable Quotes:

“The 24-hour rule is what I think is the golden rule of documentation, and it’s very simple.”

“All documentation should drive back to actually pushing you personally or your organization or your team forward into a forward state to take forward action.”

“Documentation is about, and I actually believe, it’s a problem-solving technique.”

“My book is effectively a framework for better documentation where companies can assess where they’re at, look through what they have, look at I have standards I’ve developed as well.”

Resources

Adrienne Bellehumeur on LinkedIn

The 24-Hour Rule

Tom Fox

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Principled Podcast

Principled Podcast – S9E12 – Why Arca Continental Leads with Values Over Rules in its Multinational E&C Program

What you’ll learn on this podcast episode

When it comes to driving ethical behavior in organizations, many ethics and compliance programs are beginning to focus more on leveraging company values than relying primarily on rules. But what does taking a values-based approach look like in practice, especially if you’re a multinational organization? How do talk about it with a wide range of employee populations? In this episode of LRN’s Principled Podcast, Susan Divers is joined by Gabriela Del Castillo, the chief ethics and compliance officer at Arca Continental, to discuss the importance of creating a respectful workplace and the role that E&C plays in developing ethical culture. 

Guest: Gabriela Del Castillo

Gabriela Del Castillo – Grayscale

Gabriela Del Castillo is the global chief ethics and compliance officer of Arca Continental, the second-largest Coca-Cola bottler in Latin America—and one of the largest in the world. She leads the construction of the company’s corporate sustainability through the management of ethical and compliance risks. In addition, she designs mitigation strategies—including policies, controls, and procedures—as well as communication and training initiatives for Arca’s ethics and compliance program. Gabriela also serves as the secretary of the Audit and Corporate Practices Committee for the organization’s board of directors. 

Prior to joining Arca, Gabriela was the regulatory affairs corporate manager at the food and beverage services company Empresas Polar. In this role, she helped the organization adopt risk management and compliance processes to anticipate risks and opportunities in the regulatory and legal fields. She also designed strategies to minimize costs or capture savings, based on a deep understanding of the company’s operations and stakeholders. Before that, Gabriela worked as a legal analyst for Siderúrgica del Orinoco, C.A. SIDOR, a Venezuelan steel corporation. 

Gabriela earned a master’s degree in international legal studies from Georgetown University and graduated magna cum laude from Universidad Central de Venezuela. She also received a marketing and innovation diploma from Instituto de Estudios Superiores de Administración IESA in 2017. 

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.

Categories
Sunday Book Review

Sunday Book Review: April 30, 2023 – The New Mind Edition

In the Sunday Book Review, I consider books that interest the compliance professional, the business executive, or anyone curious. It could be books about business, compliance, history, leadership, current events, or anything else that might interest me. In today’s edition of the Sunday Book Review, I return to look at some new books which caught my eye in the New Mind edition.

Today, new books from the Yale University Press:

·      Roe by Mary Ziegler

·      Mixed Signals by Uri Gneezy

·      Life by Paul Ehrlich

·      Tragic Mind by Robert Kaplan

Categories
Daily Compliance News

Daily Compliance News – April 29, 2023 – The What is Failure 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.

Stories we are following in today’s edition:

  • What is failure? (WSJ)
  • More businesses worry about doing business in China. (WSJ)
  • Will DeSantis lose his war of words with Disney? (Reuters)
  • Tit for Tat on high seas. (FT)
Categories
Creativity and Compliance

Creativity and Compliance – ‘Yes And’ In Improv and Compliance

Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the award-winning Compliance Podcast Network.

Ronnie’s company, Learnings, and Entertainment, utilizes the entertainment devices people use to consume information in their everyday, non-work lives and apply it to important topics around compliance and ethics. It is not only about being funny. It is about changing the tone of your compliance communications and messaging to make your compliance program, policies, and resources more accessible.

In this episode, discover how the famous “yes and” rule can revolutionize collaboration and communication skills, particularly regarding ethics and compliance. The hosts share their insights on effective communication and collaboration, emphasizing the importance of focusing on listening and reframing communication as an affirmation rather than an agreement. In addition, the podcast highlights the significance of soft skills for compliance officers and the power of “yes and” as a philosophy for corporate communications. Tune in for practical tips, techniques, and exercises to develop muscle memory and easily communicate important information. Take the chance to connect with a compliance program expert and gain more insights. Check out learningsentertainment.com or follow Ronnie Feldman on social media for more information. Subscribe to Creativity and Compliance now to enhance your communication skills and take your compliance program to the next level!

Key Highlights:

·      Applying Improv Rules to Compliance

·      The Power of ‘Yes And’ in Ethics Compliance

·      Soft Skills for Compliance Officers

·      Effective communication strategies for leaders

Notable Quote:

“The philosophies behind improvisation are so wonderful. If you ever meet someone who studied as an improv, they’re the most interesting, empathetic, thoughtful, collaborative, good listeners kinds of people because the philosophies and training that improvisers do have a great application to the business world, and I think even a tighter application to ethics and compliance.”

Resources:

Ronnie

Tom

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From Last to First

From Last to First: The John Aceti Story – Episode 2, Into Jr. High and High School

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.

From Last to First is an inspiring podcast that shares how difficult events in childhood can shape one’s professional career. Host Tom Fox visits with guest John Aceti, who talks about growing up in Niagara Falls, New York. In this episode, John shares his middle school experience, where an embarrassing third-grade incident led to years of harassment. Despite struggling academically and repeating the eighth grade, John found hope in the departure of the students who knew about the incident, allowing him to focus on his studies and eventually turn his grades around.

John takes us on a journey into his high school experience, where basketball and music were his passions. He opens up about his struggles with a lack of confidence in basketball and how being recognized as a star in his music group helped him realize his potential. John feels grateful for his supportive parents and the mindset he developed in college, which helped him succeed academically. With a hopeful ending, Tom thanks John for sharing his story and promises to continue the conversation in the next episode. Take advantage of this inspiration-filled episode!

Key Highlights:

· Overcoming Bullying in Junior High

· High school experience with basketball and music

· Father’s advice on education and visualization impact

· Music performance and audience engagement

 Notable Quote:

“I found myself spending more time listening to my teachers, studying, writing, and making sure that all my work was done to the best of my ability, even though in the back of my mind, I remember.”

Resources

John Aceti’s author’s page on Amazon

Categories
From the Editor's Desk

From the Editor’s Desk – April and May, 2023 in Compliance Week

Welcome to From the Editor’s Desk, a podcast where co-hosts Tom Fox and Kyle Brasseur, EIC at Compliance Week, unpack some of the top stories which have appeared in Compliance Week over the past month, look at top compliance stories upcoming for the next month, talk some sports and generally try to solve the world’s problems.

Highlights Include:

·      The cadence of compliance stories

·      ChatGPT and AI in compliance

·      Reporting and Editing compliance stories

·      Case studies in Compliance Week

·      The surprises of the NBA playoffs in 2023

·      Pitch clock in baseball

·      The Boston Bruins’ quest for all-time greatness

Kyle relates some of the upcoming Compliance Week 2023 Conference highlights from May 15-17 in Washington, DC. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link below.

Resources

Compliance Week 2023 information and registration here

Kyle Brasseur on LinkedIn

Compliance Week

Categories
The Woody Report

The Woody Report: Succession, The Final Season, Episode 5 – Kill List

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! Take advantage of the upcoming second episode of The Woody Report, where Tom and Karen bring you all the latest in pop culture, business, and more.

This week, they delve into the art of negotiation and highlight the emotional factors that can play a significant role. They also break down a masterclass in handling a potential takeover and discuss the theme of the siblings’ lack of trust in each other. The hosts praise the great dialogue and acting in a powerful scene and even relate it to their experience throwing tantrums in negotiation! They also discuss the dynamics of mergers and highlight the humor in subtle one-upmanship. Take advantage of their favorite quotes from the show, including a hilarious Scooby-Doo reference. With Tom and Karen’s infectious excitement for future episodes, The Woody Report is a must-listen for any “Succession” fan.

Highlights Include:

·      Negotiations and Emotions in Episode Analysis

·      Emotions driving actions and a planned outburst

·      Roman’s powerful soliloquy during a negotiation

·      Shiv confronts Mattson’s inappropriate behavior

·      Cultural Dynamics in a Merger and Clothing Choices

·      Analyzing Kendall and Roman’s Deal Strategy

·       Favorite lines

Resources

Karen on LinkedIn

Karen at Washington & Lee, School of Law

Tom 

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Daily Compliance News

April 28, 2023 – The $55MM Per Month 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.

Stories we are following in today’s edition:

  • 7 years later, Frank’s International settled. (WSJ)
  • The UK blocks Activism/Blizzard merger. (NYT)
  • Corruption costs Eskom $55MM per month. (AfricaNews)
  • Former Eskom CEO refuses to name names. (FT)
Categories
Compliance Week Conference Podcast

Carl Hahn on Using Data Analytics to Improve Compliance

In this episode of the Compliance Week 2023 Speaker Preview Podcasts series, Carl Hahn discusses some of his panel at Compliance Week 2023, “Data Analytics to Improve Compliance.” 

Some of the issues he will discuss in his presentations are:

  •   The expectations for compliance professionals in using data analytics in their programs;
  • Insights from both sides of the coin – government and compliance professionals on lessons in creating and cultivating data-driven compliance programs; and
  • A sense of what’s coming down the pike, including technical advancements creating opportunities for compliance, ethics, and risk professionals

I hope you can join me at Compliance Week 2023. This year’s event will be May 15-17 at the JW Marriott in Washington, DC. The line-up of this year’s event is simply first-rate, with some of the top ethics and compliance practitioners around.

Gain insights and make connections at the industry’s premier cross-industry national compliance event offering knowledge-packed, accredited sessions and take-home advice from the most influential leaders in the compliance community. Back for its 18th year, compliance, ethics, legal, and audit professionals will gather safely face-to-face to benchmark best practices and gain the latest tactics and strategies to enhance their compliance programs. And many others to:

  • Network with your peers, including C-suite executives, legal professionals, HR leaders, and ethics and compliance visionaries.
  • Hear from 75+ respected cross-industry practitioners who are CEOs, CCOs, regulators, federal officials, and practitioners to help inform and shape the strategic direction of your enterprise risk management program.
  • Hear directly from the two SEC Commissioners, gain insights into the agency’s enforcement areas, and walk away with guidance on remaining compliant within emerging areas such as ESG disclosure, third-party risk management, cybersecurity, cryptocurrency, and more.
  • Bring actionable takeaways from your program from various session types, including ESG, Human Trafficking, Board obligations, and many others, for you to listen, learn and share.
  • Compliance Week aims to arm you with information, strategy, and tactics to transform your organization and career by connecting ethics to business performance through process augmentation and data visualization.

I hope you can join me at the event. For information on the event, click here. Listeners of this podcast will receive a discount of $200 by using code TF200 on the link here.