We have been getting accountability all wrong in the compliance profession. It’s not a set of tasks – it’s a way of thinking and it has to come from the heart as well as the head. On Accountability: The Heart of Compliance Tom Fox and Sam Silverstein dig into what accountability means to the corporate compliance function and business organizations and most significantly, how to make it an integral part of your culture. In this episode Sam and I continue our three-part series to consider the current disaster Boeing finds itself in from the accountability perspective and what it might do to crawl out of the deep hole it finds itself in. In this Part 2, we consider accountability by management to the employees and other stakeholders. Some of the highlights include:
· What is the Leader’s Commitment to Accountability?
· Why should the new Boeing CEO rent out CenturyLink Field?
· How did Boeing fail in the commitment to create a safe space for employees? How can that trust be regained?
· What is an employee’s commitment to a good reputation? Why is this a long-term commitment? What can Boeing leadership do to commit to accountability in the long term?
For more information on Sam Silverstein and his work on accountability, click here.
I was recently interviewed on the Refinitiv Sustainability Perspectives Podcast, hosted by Keesa Schreane. I was joined by Charmian Simmons – Performance Director at Refinitiv, Business Development Risk Expert. We discuss ESG in 2020 and beyond together the California Consumer Privacy Act and its impact going forward.
It is always great to move to the other side of the mic. Keesa is a great host (I made her promise to come on one of my podcasts) and Charmian was excellent. We discussed a wide range of topics which every compliance practitioner needs to be cognizant of going forward. Three highlights were what’s coming in the nearest future, what are the best tools for compliance officers and which are the 3 key items to set the game in 2020?
The Refinitiv Sustainability Perspectives (RSP) is a thought-provoking podcast series where we explore the role of responsible leadership and innovation across diverse industries. From ESG investing, to sustainable finance and social impact in our communities, we’re on a journey to leverage data and intelligence to make better business decisions. Get to know the latest trends, discover best practices, and learn from industry leaders. The future is open. Join us as we move forward together to shape it.
I hope you will check it out. I am now a subscriber and you should be as well. To check it out, click here.
As far back as 2004, in Opinion Release 04-02, the DOJ realized this was an important part of an overall compliance program when it approved a proposed compliance program that had the following requirement, “Clearly articulated procedures which ensure that discretionary authority is not delegated to persons who the company knows have a propensity to engage in illegal or improper activities.” One tool that is often overlooked in the hiring process is the reference check. Many practitioners feel that a reference is not of value because prospective candidates will only list references that they believe will provide glowing recommendations of character. This leads to a pro forma reference check.
The hiring of someone who will perform business activities in compliance with anti-corruption laws such as the FCPA will continue to be as much art as science because the hiring of quality employees for senior management positions is similarly situated. But that does not mean a company cannot work to not hire those persons who might have a propensity to engage in bribery and corruption if the situation presented itself. The hiring process is just one more tool that can be utilized to build an effective and operationalized compliance program.
Three key takeaways:
- The hiring process is the first step in operationalizing your compliance program.
- The DOJ spoke to hiring as part of a best practices compliance program as far back as 2004.
- Reference checks are an underutilized part of the hiring process and a key internal HR control.
This week I have a special five-part podcast series where I am joined by Amii Barnard-Bahn to review some of the top business leadership failures of 2019. Today, we take a look at the continued leadership failures of Wells Fargo. Some of the issues we explore in this podcast include:
- The bank recently hired a new CEO, Charles W. Scharf, who is taking on one of the toughest jobs in the country.
- The bank has sustained an unremitting run of four years of crisis, unethical consumer practices with incentives that rewarded unethical behavior and poor/no controls. When will Wells Fargo finally turn the corner?
- Scharf and Wells Fargo will need to initiate a complete turnaround of culture, incentives and senior leadership.
About Amii
Amii Barnard-Bahn, JD, PCC, CCEP, CCEP-I is an executive coach who specializes in accelerating the success of legal and compliance executives and their teams. A leadership columnist for Compliance Week and Fellow at the Harvard Institute of Coaching, Amii previously shaped company culture and strategic initiatives as an executive (CAO, Chief Compliance Officer, and Chief Human Resources Officer) at companies such as McKesson and Allianz. Forbes has recognized Amii as “one of the top coaches for legal and compliance executives.”
Contact Amii
Executive Coach and Strategic Advisor
Barnard-Bahn Coaching & Consulting
Office: (510) 301-0400 | Email: amii@barnardbahn.com |website: www.barnardbahn.com
Resources
For helpful insights and actionable tips on accelerating your career, sign up for Amii’s bi-monthly newsletter at bit.ly/amiibbnews
In this episode of Life with GDPR, Jonathan Armstrong and Tom Fox are back to discuss the recent ICO announcement that it was extending the time for British Airways and Marriott to respond to its proposed fine and penalty. Some of the highlights in this episode include:
- What makes the background of the case so complex?
- What did the ICO say and why did they extend the deadline for BA to respond?
- What are some of the possible reasons for the delay?
- What if anything does Brexit have to do with this?
- In view of Brexit, will the EU be watching the ICO in this matter?
- What might be the relationship between the ICO and EU on data privacy going forward?
- Background of British Airways (BA) enforcement action.
Resources
Is the BA Fine in the Departure Lounge?
Cordery Breach Navigator
Your company culture and performance could be at stake due to how some people are making decisions in today’s world. As a leader, it’s your job to understand your risks and take action to mitigate negative effects on the company. It’s possible that you may not have realized that along with the change in generations in the workforce, there’s also been a change in decision-making processes.In today’s episode we’re going to dive into how things used to be, what has changed, and whether or not leaders can really do anything to mitigate the risk. Now is the time to level up your leadership!
If you’re looking for tangible action steps and refreshing insights to help ignite the power of your own leadership journey, sign up for my weekly leadership blog HERE.
If your business would benefit from higher-performing leaders, check out more information about the comprehensive leadership development training I do HERE.
If you want to reach out to me directly, email alyson@vanhooser.com.
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One of the conventional wisdoms about compliance training is that you will never be able to reach 5% of your workforce with compliance training because they are predisposed to lie, cheat and steal anyway. Whether they are simply sociopaths, scumbags or just bad people; it really does not matter. No amount of training is going to convince them to follow the rules, as they do not think such laws apply to them. They will lie, cheat and steal no matter what industry they are in and what training you provide to them. But knowing such people exist and they may be able to lie, con or otherwise dissimilate their way into your organization does not protect your company from FCPA liability when they inevitably violate the law by engaging in bribery and corruption. It is still the responsibility of your company to prevent and detect such conduct and then remediate if it occurs.
This is where your HR function has a dual role, with both their traditional hiring role and in a compliance function. They can work to help weed out such miscreants and to communicate your corporate values of doing business ethically, in compliance and aligned with your corporate values of integrity.
Through a structured series of questions, however, a properly trained HR professional can begin to assess whether an employee might have a propensity to engage in bribery and corruption. By adding information about your company’s values towards doing business ethically and in compliance, you can introduce this topic at either the interview evaluating process or in the promotion process. While true sociopaths will most certainly lie to you, perhaps even convincingly, by introducing the topic at such a pre-employment stage, they may be encouraged to take their skills elsewhere
Three key takeaways:
- Use the interview process to determine who will be an ethical and compliance fit for your organization.
- Consider the skill, will and fit approach.
- Ask open-ended questions.
This week I have a special five-part podcast series where I am joined by Amii Barnard-Bahn to review some of the top business leadership failures of 2019. Today, we take a look at leadership failures from Goldman Sachs and the 1MDB corruption scandal. Some of the issues we explore in this podcast include:
- The Goldman Sachs/1MDB imbroglio is one largest geopolitical scandal of the decade and may well be for the 2020s as well.
- This matter featured widespread corruption in the level of controls circumvented, at the very top levels of leadership. A settlement seems close as Goldman Sachs has announced a reserve of over $2bn to resolve the matter.
- There is hope that new CEO David Solomon will initiate a major culture change.
About Amii
Amii Barnard-Bahn, JD, PCC, CCEP, CCEP-I is an executive coach who specializes in accelerating the success of legal and compliance executives and their teams. A leadership columnist for Compliance Week and Fellow at the Harvard Institute of Coaching, Amii previously shaped company culture and strategic initiatives as an executive (CAO, Chief Compliance Officer, and Chief Human Resources Officer) at companies such as McKesson and Allianz. Forbes has recognized Amii as “one of the top coaches for legal and compliance executives.”
Contact Amii
Executive Coach and Strategic Advisor
Barnard-Bahn Coaching & Consulting
Office: (510) 301-0400 | Email: amii@barnardbahn.com |website: www.barnardbahn.com
Resources
For helpful insights and actionable tips on accelerating your career, sign up for Amii’s bi-monthly newsletter at bit.ly/amiibbnews
Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley. In episode 49, Mary Shirley, speaks with Carrie Penman, Chief Compliance Officer at Navex Global. They visit about the convergence of compliance risk and operational risk.
Once referred to by Matt Kelly as a “national treasure”, the GWIC team is pleased to feature Carrie Penman, Chief Risk and Compliance Officer of Navex Global in episode 49. Mary speaks with Carrie about the convergence of operational and compliance risk, what it’s like being a Compliance professional at a Compliance vendor as opposed to in-house in other industries and Carrie shares two of her favorite success stories with us – because GWIC believe it’s important to celebrate in the successes of other women.
Of course, we would be remiss not to tap into Carrie’s insider insights as a specialist within the world of reporting hotlines. So we ask her for a behind the scenes peak as to her thoughts on the common pitfalls companies make when rolling out reporting mechanisms and how to best troubleshoot these issues. We spend time discussing what companies can do to make their hotline a success, including concerted efforts to re-vamp your reporting line communications campaign and why it’s important to re-visit it, as well as the difficult topic of Compliance Officers sometimes being the most reluctant to speak up.
Mary wraps up the episode by sharing a simple tip for positively drawing attention to your achievements by inserting favorable adverbs when mentioning your work – something that studies show men are typically much better at than their female counterparts, so let’s level the playing field by putting the advice into action!
It’s an episode packed with high value content and as always, Carrie Penman is a crowd pleaser.
Join the Great Women in Compliance community on LinkedIn here.