The UK and EU coordinate on Belarus sanctions and the Kitchen reviews what’s cooking in this area.
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Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley. Mary and Lisa are delighted to release a special episode that honors and celebrates Pride month. There is even distinctive and special cover art for this episode – check it out!
Our guest today is Ryan Rushing, a graphic design artist at Broadcat. We discuss two main themes with Ryan, leveraging off her specialist skillset of communicating by way of designed documentation as well as how to be a better ally to transgender colleagues in the workplace as well as in a wider societal context. Ryan came out as trans during the pandemic and shares a piece of her story as well as some considerations to help trans and other LGBTQ+ members feel included and respected.
This is a must listen episode and the perfect way for the GWIC team to close the season. Lisa and Mary wish their listeners the joy and beauty of all the colors of the rainbow, always and a very happy Pride Month. They sign off for two weeks and invite you to be a part of their kickoff episode for next season which will be an impromptu Q&A. Neither Lisa nor Mary will have time to prepare their answers in advance.
Send your questions for Lisa to Mary and your questions for Mary to Lisa!
Look out for the next GWIC episode which will be out on July 21, 2021!
For those of you in the northern hemisphere, it is the season for beach reads and you may be traveling after a long break. For your time off, you can pick up a copy (or download) “Sending the Elevator Back Down: What We’ve Learned from Great Women in Compliance” (CCI Press, 2020).
If you’ve already read the booked and liked it, will you help out other women to make the decision to leverage off the tips and advice given by rating the book and giving it a glowing review on Amazon?
As always, we are so grateful for all of your support and if you have any feedback or suggestions for our 2021 line up or would just like to reach out and say hello, we always welcome hearing from our listeners.
You can subscribe to the Great Women in Compliance podcast on any podcast player by searching for it and we welcome new subscribers to our podcast.
Join the Great Women in Compliance community on LinkedIn here.
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. This week Matt and Tom take a deep dive into the first FCPA enforcement action involving a company in 2021, the Amec Foster Wheeler global anti-corruption enforcement action. Some of the issues we consider are:
- What were the underlying facts?
- Were red flags missed, consciously avoided or outright ignored?
- Where was compliance?
- How corrupt was the culture of Foster Wheeler?
- What does this mean for compliance going forward?
Resources
Matt in Radical Compliance
Foster Wheeler’s FCPA Lessons
Tom in the FCPA Compliance and Ethics Blog
Not a Siren’s Song
Silk Shirts and Corruption
Ba-da-Bing; Ba-Da-Bing
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Loki, Episodes 1-3
Tom Fox and Megan Dougherty are back to review the Disney series starring the Marvel Cinematic Universe character, Loki, in the new series, appropriately enough named Loki. In this special catch up episode, they take a look at episodes 1-3. Each episode will feature a review of the synopsis, Cookies and other cool stuff and then go through some of the questions they have from each episode. It will be a rollicking great time. Join us for all 10 episode. Spoiler Alert-if you have not seen the episode, Tom and Megan will be taking a deep dive into all of the storylines.
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Iran Update
The Kitchen reviews the DOJ’s recent seizure of websites utilized by Iranian SDNs; UK issues guidance on financial restrictions under its sanctions on Russia.
How to manage if a conflict of interest arises in your organization?
Scenario: It’s Friday, July 3, and the General Counsel is on holiday. At 4 PM, you get a call from someone who tells you he has a deal with the CEO to be put on the Board of Directors. He further says he’s held up his end of the agreement to loan the CEO $5MM for a Board seat. He says he has the email traffic and will file a suit unless he is named to the Board within three days. He says the GC has approved this deal and is on the email trail.
What can you do? You review the code of conduct and believe it’s a Conflict of Interest (COI). There are four new Board members. Did they have similar arrangements?
In this episode, Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation, thresh out what to do if you are in a similar scenario and assess the best approach and manage corruption within your organization.
Key takeaways in the episode:
✔️ Make your first call with outside counsel. If members of the BOD are suspect, you wouldn’t want to tip them off by calling the Audit Committee chair – especially if that individual may be part of the problem.
✔️ Push to have outside counsel perform the special investigation instead of the BOD. That way, the results are above reproach.
✔️ Board membership should be vetted by counsel, especially when it comes to COI.
✔️ Reiterate that disclosing a conflict of interest is required, but that doesn’t mean that the conflict will cause a problem. Conflicts have to be managed. Some of them will result in the Board, the CEO, executive leadership, or members of the workforce not being able to take the actions they want to take.
✔️ Use COI incidents as an opportunity to retrain, reeducate and build awareness with the rest of the workforce on conflicts of interest and the code of conduct.
✔️ Train people in person on conflicts of interest and use real-life examples. COIs can be much broader, and ensure you name those. It can be sending business to a relative, a wife, or a child on the payroll can be a wide variety of things.
✔️ When you’re appointing so much of the Board and looking for people to help run your company, full diligence is really important.
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Welcome to SURVIVE AND THRIVE, the newest addition to the Compliance Podcast Network. This is a podcast where we unpack compliance, crisis disasters and walk you through all the red flags which appear, and give you some lessons learned going forward. This show is hosted by Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation.
Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.
Brad Moore, the President and CEO of Global Cannabis Applications Corp, started his career in marketing, working at Kodak, where he got an exceptional education in how to sell. His company is creating innovative strategies and solutions in the cannabis space. Always someone to be on the cutting edge of technology. He and Tom are discussing blockchain technology, navigating an industry without nearly enough data, and helping end-users make the best possible decisions.
Push-Pull Education
Brand and brand awareness is how you “cross the chasm” between an idea and the market. In his current industry, there is a cultivator at one end and a consumer at another, but the data and understanding that should help regulatory bodies facilitate communication between the two aren’t available. This means there is a lot of work that has to be done in education. It’s using a push-pull strategy to provide the education required to do certain things or communicate certain things, and that’s the pull strategy – the education, and that is what is going to get the company over the chasm.
Unique Challenges
One of the challenges Brad faces in his company is the huge variances that can occur between plant to plant. It’s not like a formulation that goes into a pill or a vaccine, so the different regulatory bodies have had to make decisions about how to tax and regulate it. To make their products available, they have to abide by rules made by people who don’t have all of the data. Brad is using innovative technologies to try and change that. Advocacy for patients informs a lot of his work, particularly making sure that end users have all of the information that they need to make informed decisions.
The Importance of Branding.
He talked about the Brand “Citizen Green” and what it needed to do for the company and for the market. He makes the comparison to a parent company and its subsidiary brands. Ultimately it means one thing, however, which is better outcomes for medical cannabis patients – Citizen Green, that is what it means.
Process-Driven Approach
Tom asked Brad about the process-driven approach used at GCAC, and Brad describes the different stakeholders involved in the company and the industry as a whole, and how he spent a great deal of time learning from different countries and how they arrange different processes in the industry. This is how they started to identify areas for improvement and innovation. He is now using blockchain technology to help consumers learn about products – which also helps suppliers and retailers get the information they need to provide good service and better products. Thanks to Blockchain technology, there are now user experience data attached to every gram of product, which is critical because plants change.
Partnerships and Looking to the Future
Jeffrey Hayzlett, who Brad first worked with at Kodak has taken a role as chairman of the board at GCAC, and Brad explains how their partnership has evolved over time. This kind of good working relationship with experts is important during uncertain times. Brad goes on to talk about how the blockchain basis of the company has been valuable during the pandemic. He believes that the blockchain mechanism he is using to solve problems in the cannabis industry is going to be very broadly applicable to any business dealing with consumables, or that otherwise deal with a lot of variance in their products.
Resources
Brad Moore on LinkedIn
Cannappscorp.com // Info@Cannappscopr.com
CitizenGreen.io
In today’s edition of Daily Compliance News:
- Can voluntary cooperation with DOJ lead to US jurisdiction? (Economic Times)
- Facebook anti-trust case dismissed. (WSJ)
- Juul settles first of several lawsuits for ads targeting minors. (NYT)
- Corrupt Angolan purchase on way to dissolution. (ICIJ)
The European Commission served up new and improved model contractual clauses for data transfers under the GDPR. Important dates are attached and the Kitchen took a look at this development.