Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley. Like Compliance, Corporate Social Responsibility (CSR) is an area which has had an increasing spotlight over the past few years. As a result, both of these functions have evolved and are more aligned in the past. In this episode, Lisa Fine visits with Alison Taylor. One of the trailblazers in this area is Alison Taylor, who is the Executive Director of Ethical Systems, a Senior Advisor at BSR and an adjunct professor at NYU Stern School of Business.
Alison joins Lisa Fine on Great Women in Compliance to discuss CSR and Compliance, how they intersect, and where there may be tensions between them. They discuss how ethics and ethical behavior are the underpinnings of both areas and how this becomes even more important in times like now, with COVID-19.
Alison has worked all over the world and discusses her experiences as a woman in some of her roles, including what she wishes she knew when she started out.
This episode was released the week prior to Compliance Week, where Lisa is on a panel that Alison is moderating called Week. “The CCO & CSR: The Impact of Corporate Social Responsibility on Compliance Programs.” Compliance Week has been a great supporter of women in compliance (as well as the podcast), and now they have introduced us to another #GWIC.
Join the Great Women in Compliance community on LinkedIn here.
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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. In this podcast Matt Kelly and Tom Fox take a deep dive into the compliance job market, during the middle of Covid-19 health crisis and into the rest of 2020 and beyond.
Some of the highlights include:
- The Radical Compliance Job Report is growing not lessening.
- Why is the market for CCO types frozen and wrecked?
- Will a thaw come in the second half of the year?
- Does Covid-19 hasten the move to more tech solutions in the AML compliance world and beyond?
- What is happening with salaries?
- What industries are bullish on compliance hiring?
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. This month, I visit with Ellen Hunt, Senior Vice President – Audit, Ethics & Compliance Officer. Ellen is a lawyer, ethics & compliance professional, and chief audit executive. She has extensive management experience in designing, implementing and operating ethics and compliance programs including board governance and reporting, designing ethics education, creating policy management frameworks, managing enterprise and compliance risk processes as well as handling investigations and regulatory inquiries. Utilizing AARP’s enterprise risk management profile, she re-designed how AARP conducts its annual audit planning process to identify audits that relate to the organization’s must significant risks and incorporated the use of data analytics into audit execution.
Ellen like many who are in compliance, came to it by (1) being drafted and (2) from the legal function. When she began, compliance was legalistic, rules-based; largely seen as an insurance policy in case there was a compliance failure. It has changed to a business process and every CCO needs to understand the business of their organization. We explore what skills you need to develop to grow in the compliance profession.
There are numerous reasons to put some serious work into your policies and procedures. They are certainly a first line of defense when the government comes knocking. The 2012 FCPA Guidance made clear that “Whether a company has policies and procedures that outline responsibilities for compliance within the company, detail proper internal controls, auditing practices, and documentation policies, and set forth disciplinary procedures will also be considered by DOJ and SEC.” And by using the word “considered” it is clear that this means the regulators will take a strong view against a company that does not have well thought out and articulated policies and procedures; all of which are systematically reviewed and updated. Moreover, having policies written out and signed by employees provides what some consider the most vital layer of communication and acts as an internal control. Together with a signed acknowledgement, these documents can serve as evidentiary support if a future issue arises. In other words, the “Document, Document, and Document” mantra applies just as strongly to this area of anti-corruption compliance.
The specific written policies and procedures required for a best practices compliance program are well known and long established. The 2012 FCPA Guidance stated, “Among the risks that a company may need to address include the nature and extent of transactions with foreign governments, including payments to foreign officials; use of third parties; gifts, travel, and entertainment expenses; charitable and political donations; and facilitating and expediting payments.” Policies help form the basis of expectation and conduct in your company. Procedures are the documents that implement these standards of conduct.
Three key takeaways:
- The Code of Conduct, together with written compliance policies and procedures form the backbone of your compliance program.
- The DOJ and SEC expect a well-thought out and articulated set of compliance policies and procedures.
- The Fair Process Doctrineholds for the application of policies and procedures.
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by Megan Dougherty, co-founder of One Stone Creative. She posed the question “Are you Pod-curios?” so I asked her to come on the show and explain how and why people are turning to podcasts during the coronavirus health crisis.
Leigh Vickery of Level 2 Legal, joins Tom Fox on this week’s show to discuss her company’s innovative managed services for the legal and compliance industry. She shares how they help clients get to the next level using a strategic combination of data and behavioral economics.
Helping People Solve Problems
Leigh shares her eclectic career background and how she came to the legal industry without any legal training. “I love helping people solve problems and… seeing the big picture and the patterns and processes across the business or industry,” she says. Level 2 Legal shares her vision: they see themselves as problem solvers whom their clients can count on. “How that manifests itself now is in e-discovery, compliance investigations, solving legal problems, or helping our clients understand how those legal issues affect their business outcomes.”
Long Term Relationship-Builders
Success depends on staying nimble, Leigh tells Tom. “We’re very much long term relationship-builders as a company,” she points out. As things change, Level 2 Legal is able to innovate to stay relevant. This is how they built the company from the first. Leigh comments that it took commitment, money, collaboration, and a willingness to fail fast and change direction. Her job is to drive those initiatives and keep the company looking around the corner.
A Different Perspective
Tom is intrigued by Leigh’s statement that she brings a new perspective to problem-solving as well as innovation. He comments that a general counsel’s job is to protect the company from legal violations, whereas a compliance officer must remediate those violations. Ironically, however, most compliance officers were first general counsels. He says that his objective with this podcast is to bring innovative solutions to compliance officers to help them in their role. Leigh responds that every company should have someone who thinks differently to help the business innovate and improve.
A Different Approach
“Our services are completely designed to enable [our clients] to do what they need to do better, to help them predict where they’re going to have a problem…” Leigh says. She describes her company’s role as being there to help their clients look good. She explains that they’re able to fulfill their role through a strategic combination of data and behavioral economics. Their approach is collaborative, holistic and creative, she says; they are playing the long game. Tom asks her to define what it means to play the long game. She responds that it’s about thinking for the next generation. Because her company used this approach, they were able to survive and thrive through the present crisis. “The value of thinking long term is just table stakes now to be able to survive and thrive,” she comments.
Resources
Level2Legal.com
Call Leigh Vickery at (903)245-9183
In the Episode, I am joined by Joel Androphy, co-founder at Berg & Androphy. Joel is well-known literally across the country as a white-collar defense lawyer and plaintiff’s counsel in high-profile False Claims Act litigation. With the ongoing Trump Administration’s bailouts and stimulus packages, there will be great temptations for fraud. There have already been several high-profile cases of companies returning bailout monies to which they were not entitled. In this podcast we consider the role of the FCA in helping the US government fight fraud, waste and abuse.
Some of the highlights include:
- Androphy believes the coronavirus bailout will cause great amount of fraud.
- What is the role of the FCA in fighting government fraud, waste and abuse?
- Why does Androphy believe that citizens who bring FCA cases are doing civic duty?
- What are the different types of fraud perpetrated in government contracting?
- Why is Androphy on a mission to have the federal bailout dollars benefit the American worker and not the American fraudster.
For more information on Joel Androphy, check out the firm website here.
In today’s edition of Sunday Book Review:
- Flash Crash: A Trading Savant, a Global Manhunt, and the Most Mysterious Market Crash in History by Liam Vaughn
- The Price of Peace: Money, Democracy, and the Life of John Maynard Keynes by Zachary Carter
- The Hour of Fate by Susan Berfield
- Sunny Days by David Camp
