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Greetings and Felicitations

Winnie the Pooh Explains Compliance: Part 1 – Tigger and Sales

This week I begin a five-part series on compliance as seen through the lens of Winnie the Pooh and the characters who live in the Hundred Acre Woods: Pooh, Eeyore, Tigger, Kanga & Roo, and Piglet. This episode begins with Tigger and the sales function’s role in compliance.

Tigger first appears in the House at Pooh Corner when he arrives at Pooh’s doorstep in the middle of the night. Tigger takes up residence with Kanga and Roo. He becomes great friends with Roo, and Kanga treats him like she does her son. Tigger seems to have boundless energy, often too much energy for some of the other denizens of the Hundred Acre Wood. Rabbit, who is constantly exasperated by Tigger’s constant bouncing; Eeyore, who is once bounced into the river by Tigger; and, finally, there is Pooh’s good friend Piglet, who always seems a little nervous about the new, large, bouncy animal in the Hundred Acre Wood.

Tigger seems like the epitome of a top salesperson. He is very confident, has quite an ego, and has a high opinion of himself. He always seems to have great energy and optimism, and though always well-meaning, he can also be mischievous, and his actions have sometimes led to chaos and trouble for himself and his friends. Tigger often undertakes tasks with gusto, only to realize they are not as easy as he had originally imagined. Tigger, unique as ever, refers to himself not as a tiger but as a “Tigger”, and when he introduces himself, he announces the proper way to spell his name, and that is “T-I-double-Guh-Er”, which spells “Tigger”.

Tigger seems like a great way to think about sales incentives from the compliance perspective. Much like Tigger, most sales folks have their hearts in the right place, even if their actions cause trouble for themselves and others.

At the end of the day, Tigger is good-hearted, even if his over-exuberance can sometimes lead to misadventures. If you properly incentivize your sales team, you will hopefully keep their over-exuberance into being simply good-hearted as well.

Join me tomorrow when I consider Kanga, Roo and the Compliance Ombudsman.

Categories
Career Can D0

A Seamless Path to the IT Industry with Jubee Vilceus

 

In this episode of Career Can Do, Mary Ann Faremouth chats with Jubee Vilceus. Jubee is Managing Partner at Yellowtail.tech, an organization that helps interested career seekers without an IT background get jobs in the industry. Jubee shares how Yellowtail.tech prepares its students with training and real-world experience.  

 

 

In recent times, many companies have been reorganizing, cutting back, and even closing down, which have left many people without jobs. People are now trying to decide how they’re going to transfer their skills or get into something else entirely. The demand for skills in the IT industry is very real and very high in this digital age, and Yellowtail.tech is helping close the gap by training interested persons with no IT background or education to speak of. 

 

Certification at Yellowtail.tech can take 6 to 9 months depending on which program you choose. However, Jubee advises, it’s a year long commitment. Not only do you need certification and skills, but you also need hands-on experience to apply the knowledge you’ve gained. For this reason, Yellowtail.tech also supplies its students with access to internships.

 

Resources

Jubee on the web | Facebook | Instagram | LinkedIn

 

Faremouth.com

 

Categories
The ESG Report

Corporate Culture and ESG with Ty Francis

 

Tom Fox welcomes renowned compliance leader, Ty Francis, to the ESG Report! Ty is the Chief Advisory Officer at LRN; he leads the company’s worldwide ethics and compliance consulting, ESG, and community outreach strategy. In this week’s episode, Ty and Tom discuss LRN’s new report, Assessing Corporate Culture, and how it relates to ESG. 

 

 

The Genesis of the Assessing Corporate Culture Report

Tom asks Ty about the genesis of the LRN report. This is the second report LRN produced; the first one was about activating culture and ethics in the boardroom. Their previous research led the team at LRN to realize that most corporate boards did not understand culture. Ty says, “Over the last 10 years culture is so high on those lists, but when you look further into the survey and ask them what they’ve done to measure this culture, it’s nonexistent.” Therefore, LRN sought to discover the general opinion on culture and ethics compliance and provide a roadmap on how to activate these skills within a company. 

 

Roadmap for Building Corporate Culture

Tom highlights how the report can be used as a roadmap to build culture. Ty says that building corporate culture starts with defining ethical culture. Ethical culture is the codification of what an organization stands for and the systems that support those beliefs; the core architecture should be reinforced by leadership in how they model desired behavior. The second step in building culture is getting to know the most valuable members within your company, in each department. Culture is extremely important for building relationships within a company and allowing people to hear opinions from all sides. 

 

The Relationship Between ESG and Corporate Culture

The culture within a corporate setting has always been an ESG issue. The governance aspect of ESG is directly related to culture as it is something that companies should have been implementing for years. Ty remarks, “It shows the company’s values across the board, and I think when you have a mismatch of what the company says it’s doing and what they are really doing, that can fragment any ability for a company to demonstrate that it is really a forward-thinking, future-expanding company.” The governance is to be upheld by the board, stewards, stakeholders, and managers. He lists five key considerations for boards: 

  • prioritizing culture on the board agenda, 
  • challenging the board’s culture, 
  • mentoring and monitoring, 
  • articulating the desired culture, and 
  • establishing clear communication.

 

Looking Ahead

Acknowledging the new legal and regulatory requirements, public pressure and the evolution of thinking surrounding corporate culture, Tom asks Ty if he believes that boards will maintain the corporate culture into 2025 and beyond. Ty believes these pressures will force boards to manage and maintain the corporate culture. 

 

Resources

Ty Francis | LinkedIn | Twitter

LRN | LRN Report – Assessing Corporate Culture | LinkedIn | Twitter | LRN Report – Benchmark of Ethical Culture |

 

Categories
FCPA Compliance Report

Mary Inman on the Current State of Whistleblowing


In this episode of the FCPA Compliance Report, I am joined by Mary Inman, partner at Constatine Cannon. We look at recent developments in whistleblowing and how the Ukraine War has increased the visibility of whistleblowers. Highlights of this podcast include:

  1. Whistleblower Reward Program at the US Treasury Department/FinCEN – what is its relevance to corruption, anti-money laundering and the Ukraine conflict.
  2. The House Committee on Financial Services voted to strengthen the U.S. Treasury’s Anti-Money Laundering (AML) whistleblower program.  What does this mean for this  nascent program?
  3. How does a minimum whistleblower reward threshold, whistleblower incentives and injects more certainty into the Anti-Money Laundering whistleblower program.
  4. How does expanding AML whistleblower rewards to cover laws applicable to Russian sanctions, Congress is enlisting the help of the private citizenry.
  5. Lisa Monaco recently spoke about the government relying on corporations to ID instancesof money-laundering and other activities to help enforcement Russia economic sanctions and broader trade sanctions. Do you see private citizen or other whistleblowers as a key component of this fight?
  6. How has the Ukraine War raised the profile of whistleblowers and whistleblowing?
  7. Starting with SOX, then Dodd-Frank and the AML Law of 2020 has the US government began to understand whistleblowers as a key component in the fight against fraud, waste and abuse.
  8. Has the government embraced these same strategies and tactics in the wider fight against corruption?
  9. Tribute to Chuck Grassley for his advocacy of whistleblowers.

 Resources
Mary Inman on Constantine Cannon website

Categories
Blog

Farewell to Lt. Uhura

The Star Trek world and family lost one of its dearest members on Sunday with the passing of Nichelle Nichols, Lt. Nyota Uhura. George Takei spoke for many of us when he wrote on Twitter, “For today, my heart is heavy, my eyes shining like the stars you now rest among, my dearest friend.” The role of Lt. Uhuru was truly ground-breaking for television in the 1960s; a black woman was an officer of a naval ship (well OK combined services); manning a key role on the executive leadership team of the Starship Enterprise. For a television show which premiered only a couple of years after the landmark Civil Rights Act of 1964, her role was almost revolutionary.

Indeed, as noted by Jake Tapper on Twitter, perhaps her biggest fan was Dr. Martin Luther King. After the first season of the show, she was considering leaving but reconsidered after meeting Dr. King at an NAACP fundraiser. She said he introduced himself as a fan and grew visibly horrified when she explained her desire to abandon her role, one of the few non-servile parts for Blacks on television. Nichols told Entertainment Tonight, “Because of Martin, I looked at work differently. There was something more than just a job.” As reported in The Hollywood Reporter, “He told me that Star Trek was one of the only shows that his wife Coretta and he would allow their little children to stay up and watch,” she recalled. “I thanked him and I told him I was leaving the show. All the smile came off his face and he said, ‘You can’t do that. Don’t you understand, for the first time, we’re seen as we should be seen? You don’t have a Black role. You have an equal role.’ “I went back to work on Monday morning and went to Gene’s office and told him what had happened over the weekend. And he said, ‘Welcome home. We have a lot of work to do.’ Said Roddenberry in the documentary, “I was pleased that in those days, when you couldn’t even get Blacks on television, that I not only had a Black but a Black woman and a Black officer.””

Adam Bernstein, writing in the Washington Post, said, “Nichelle Nichols, an actress whose role as the communications chief Uhura in the original “Star Trek” franchise in the 1960s helped break ground on TV by showing a Black woman in a position of authority and who shared with co-star William Shatner one of the first interracial kisses on American prime-time television.” He went on to say, “On the bridge of the starship Enterprise, in a red minidress that permitted her to flaunt her dancer’s legs, Ms. Nichols stood out among the otherwise all-male officers. Uhura was presented matter-of-factly as fourth in command, exemplifying hopeful future when Blacks would enjoy full equality.”

On the subject of that kiss, the first inter-racial kiss went to Sammy Davis, Jr. and Nancy Sinatra but was simply a “peck on the cheeks.” Her kiss with Shatner was anything but a peck on the cheek. Bernstein wrote, “Her most prominent “Star Trek” moment came in a 1968 episode, “Plato’s Stepchildren,” about a group of “superior” beings who use mind control to make the visiting Enterprise crew submit to their will. They force Kirk and Uhura, platonic colleagues, to kiss passionately.” But if you watch the episode, I as recently did for its upcoming treatment on my podcast series Trekking Through Compliance, you will see that it is something very different than a passionate kiss, as it was forced onto the characters of Kirk and Uhura by beings who controlled their minds. In rewatching the entire episode, it is a troubling episode with this kiss perhaps the most troubling seen.

The Hollywood Reporter said of that kiss, “When NBC execs learned about the kiss during production, they feared stations in the Southern states would not air the episode, so they ordered that another version of the scene be filmed. But Nichols and Shatner purposely screwed up every additional take. Finally, the guys in charge relented: ‘To hell with it. Let’s go with the kiss,” Nichols wrote in her 1994 book, Beyond Uhura: Star Trek and Other Memories. “I guess they figured we were going to be canceled in a few months anyway. And so the kiss stayed.”

Even though Star Trek, the Original Series went off the air in 1969, “Nichols’s continued association with Uhura at Trekkie conventions led to a NASA contract in 1977 to help recruit women and minorities to the nascent space shuttle astronaut corps.” Nichols said of that recruiting effort, “I went everywhere. I went to universities that had strong science and engineering programs. I was a guest at NORAD [the North American Aerospace Defense Command], where no civilian had gone before. “At the end of the recruitment, NASA had so many highly qualified people. They took six women, they took three African-American men … it was a very fulfilling accomplishment for me.”

In many ways, the fight for equality that Nichols participated in is still ongoing. Diversity, Equity and Inclusion (DEI) is under attack in many states across the nation, with states such as Florida and Texas considering legislation which prevents companies from DEI initiatives such as those by pioneers such as Nichols.

Sunday, we lost another pioneer in the fight for DEI and social justice but from a very different world from Nichols. That pioneer was Bill Russell, and his world was sports. Please join me tomorrow when I pay tribute to Russell.

Categories
Daily Compliance News

August 1, 2022 the Farewell to Lt. Uhuru edition

In today’s edition of Daily Compliance News:
• UAW is trying to shed the legacy of corruption. (NYT)
• Former Blue Bell CEO goes to trial. (Reuters)
• Bill Russell passes. (AndScape)
• Nichelle Nichols dies. (The Hollywood Reporter)

Categories
Sunday Book Review

July 31, 2022 the Integrity and Ethics edition

In today’s edition of Sunday Book Review:

·      Net Positive: How Courageous Companies Thrive by Giving More Than They Take by Andrew S. Winston

·      Defining Moments: When Managers Must Choose Between Right and Right by Joseph L. Badaracco Jr.

·      Business Ethics by Stephen M. Byars and Kurt Stanberry

·      Business Ethics: Best Practices for Designing and Managing Ethical Organizations by Denis Collins

Resource

Best 12 Ethics Books to Read in 2022 in Teambuilding.com.

 

Categories
Popcorn and Compliance

Schindler’s List

In this edition of Popcorn and Compliance, Richard Lummis and Tom Fox review the Best Picture-winning movie Schindler’s List. Highlights include:

  • Movie Storyline
  • How did it make you feel?
  • Leadership Lessons
  • Ethical Lessons
  • Servant Leadership
  • Final Thoughts on the Banality of Evil
  • Shoah and Schindler’s list

Resources

10 Leadership Lessons from Schindler’s List

Oskar Schindler-a Sheep in Wolf’s Clothing

Evaluating Ethics and Leadership in Schindler’s List

Ethics on Film: A Discussion of Schindler’s List

Categories
Daily Compliance News

July 30, 2022 the Bend Every Rule edition

In today’s edition of Daily Compliance News:

  • Why Rotterdam balked. (NYT)
  • No deal, no audit. (Reuters)
  • Lawsuit over SEC whistleblower award. (WSJ)
  • Debt markets must pay attention to corruption. (FT)
Categories
Corruption, Crime and Compliance

Episode 240 – The CCO’s Role in an Effective Compliance Program

I have been — and continue to be– hyper-focused on the proper role and responsibilities of Chief Compliance Officers. Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called hot issues — ESG, Diversity, Climate Change, Threats to Democracy, Cybersecurity and Data Privacy, each of which is an important component and focus for organizations. All of these issues intersect, are interdependent and should be addressed through organizational commitment. But I want to take a step back and return to an issue of importance — the proper role of CCOs. To do so, we need to remind everyone about basic requirements, lessons learned and ways forward to meet the fast-changing times. CCOs have to maintain and then advance their positions. In my view, given the interdependence of all the important issues mentioned above, the role of the CCO has become even more critical. In this episode, Michael Volkov reviews the standards applicable to the CCOs function in an effective compliance program.