Tag: CCO

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Innovation in Compliance

Making Compliance Training Memorable: Gamechanger 4 – Make Learning Playful

There is not much I enjoy more than sitting down with one of the innovative thinkers in compliance, Carsten Tams to find out what is on his mind regarding compliance. Tom Fox recently had the opportunity to do so on the topic of making compliance training memorable. Over this short, five-part series, we will introduce the problem and challenges and then provide you with four proven strategies for success in your compliance training.

In this concluding Episode 5, we discuss how making ethics and compliance training playful can enhance learning.

Our learning brain likes games. When people shift into a playful state of mind, they immerse themselves more deeply into the learning activity. Their mood brightens, their mind opens up, and they are intensely focused and more receptive to new information. Playful learning supports a deeper understanding of concepts, better recall of knowledge, and better transfer of skills to novel problems.

They explore the concept of the ‘Magic Circle’ in gaming, which engenders an immersive, playful state of mind that fosters openness and engagement. By employing game-based learning experiences like the ‘Ethics Kit Find Your Path’ card game, the discussion showcases how ethical scenarios can be addressed in an interactive, fun way.

Through the use of commitment, action, and resource cards, employees engage in collaborative problem-solving related to their organization’s ethical dilemmas. The episode emphasizes the importance of experiential, social, and strength-based learning, arguing that an engaging user experience (UX) in training not only makes learning enjoyable but also more effective in reinforcing ethical behaviors within organizations.

Highlights and Key Issues Discussed:

  • Introducing Playful Learning in Ethics and Compliance
  • The Magic Circle: A Concept for Playful Learning
  • Implementing Playful Learning: The Ethics Kit Card Game
  • Benefits and Outcomes of Playful Learning Experiences
  • Expanding Playfulness Beyond Games: Engaging Training Delivery
  • Key Takeaways from the Series

Resources:

Suggested Readings

  • Zosh, J. M., Hopkins, E. J., Jensen, H., Liu, C., Neale, D., Hirsh-Pasek, K., Solis, S. L., & Whitebread, D. (2017). Learning through play: a review of the evidence (white paper). The LEGO Foundation, DK.
  • Parker, Rachel & Thomsen, Bo & Berry, Amy. (2022). Learning Through Play at School – A Framework for Policy and Practice. Frontiers in Education. 7. 10.3389/feduc.2022.751801.

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Blog

Making Ethics & Compliance Training Memorable: Part 5 – Making Compliance Training Playful

There is not much I enjoy more than sitting down with one of the innovative thinkers in compliance, Carsten Tams, to find out what is on his mind regarding compliance. I recently had the opportunity to make Ethics and Compliance (E&C) training memorable. We explored this topic over a five-part podcast series on the Innovation in Compliance podcast on the award-winning Compliance Podcast Network.

Over the next five blog posts, I will also explore these topics in the blog format. I will introduce the problem and challenges and then provide you with four proven strategies for success in your compliance training. I will deeply dive into why traditional E&C training often fails to engage employees and needs more impact on their behavior despite significant investments. In this concluding Part 5, we consider how a compliance professional can create playful and fun compliance training to increase employee engagement.

We began with the question, ‘Why is it important to make ethics and compliance training playful?’ Tams noted that there is a concept in gaming called the “magic circle.” This means that as “we enter into a play frame of mind, we enter this magic circle, where we become more open to new information. Play facilitates experiential learning, where we actively engage all our senses and enter a generative mode. We become protagonists in our learning journey in a play situation, turning training into an adventure. Games also lend themselves well to social learning. Strength-based, social, and experiential learning converge in the play. There is evidence supporting the positive learning outcomes facilitated by playful learning.”

We turned to some examples of playful ethics and compliance training and how it can incorporate some of the other concepts we have explored over this series, such as strength-based training, experiential learning, and the social aspect. Tams noted he developed a game-based ethics learning experience called “The Ethics Kit: Find Your Path,” a “card game for three to five participants. Players start by selecting a scenario derived from the company’s ethics code, such as anti-harassment, money laundering, or anti-discrimination. One player, the Pathfinder, devises a strategy to address the issue, supported by others using commitment, action, and resource cards. Participants engage in a self-guided, open-ended experience, using their ingenuity and creativity to bring diverse perspectives together. This resembles real-life situations, and players are cast as heroes who intervene to stop unethical behavior. This aligns with the strength-based perspective, where employees are seen as ethical agents rather than potential delinquents.”

Tams led a training session at UNESCO using this approach, with 50 senior managers participating. He noted that the room was filled with chatter and problem-solving, which he believed “demonstrated the effectiveness of this approach. Through this process, participants realize they are not alone in caring about ethics, which builds confidence and fosters a supportive environment.”

Tams also believes playfulness is how the training is delivered, such as using animation, music, or cool graphic designs to drive engagement, as engaging different senses can add significant value. However, he cautioned that these elements should not be used as gimmicks and that ensuring meaningful learning is crucial. If you address learners as ethical agents who can actively uphold moral values rather than potential rule-breakers, then playful elements like cartoons and humor can be practical. Otherwise, it becomes merely cosmetic and entertaining but not empowering.

Making ethics and compliance training fun and playful can transform an organization’s approach to ethical behavior. Organizations can create engaging, meaningful, practical training experiences by integrating playfulness into learning. This approach enhances individual skills and fosters a supportive and moral culture.

To implement playful learning in your organization, consider the following steps:

  1. Incorporate Game-Based Learning: Use games like “The Ethics Kit” to create interactive and engaging learning experiences.
  2. Leverage Multimedia Elements: Enhance training with animation, music, and graphic designs to make the content more engaging.
  3. Focus on Meaningful Learning: Ensure the content is relevant and meaningful to the learners, recognizing them as ethical agents.
  4. Build a Supportive Culture: Foster a culture of ethics by encouraging continuous dialogue and support among employees.

By taking these steps, compliance professionals can create a robust and engaging ethics training program that empowers employees to act ethically and supports a culture of integrity within the organization.

We concluded by summarizing key points from our five-part series. First, the user experience (UX) is crucial. Ethics can only be practical if it is engaging. Recipients must feel that the content speaks to them and is meaningful. The importance of UX, which is well-established in product design and design thinking, should be applied to ethics and compliance training.

Second, conventional compliance training often should be included in education and learning. Many compliance training programs need to move the needle on behavior change because they need insight from behavioral sciences, philosophy, psychology, and learning professionals. Integrating these perspectives can enhance training effectiveness.

Third, the four-game changers we have discussed—strength-based learning, experiential learning, social learning, and playful learning—are well-supported by research. These strategies are not new; they have been discussed and validated for over a century. Compliance professionals can benefit from incorporating these proven methods into their programs.

We hope you will consider one or more concepts in this podcast and blog post series. Please feel free to reach out if you have any questions or want to explore these topics further.

Tom Fox can be reached at tfox@tfoxlaw.com

Carsten Tams can be reached at carsten.tams@emagence.com

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Compliance Tip of the Day

Compliance Tip of the Day: Enhancing Compliance Through Automation

Welcome to “Compliance Tip of the Day,” the podcast where we bring you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements.

Whether you’re a seasoned compliance professional or just starting your journey, our aim is to provide you with bite-sized, actionable tips to help you stay on top of your compliance game.

Join us as we explore the latest industry trends, share best practices, and demystify complex compliance issues to keep your organization on the right side of the law.

Tune in daily for your dose of compliance wisdom, and let’s make compliance a little less daunting, one tip at a time.

In today’s episode, we explore how, by using data-driven solutions, CCOs and compliance professionals can automate compliance programs.

For more information on the Ethico ROI Calculator and a free White Paper on the ROI of Compliance, click here.

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Innovation in Compliance

Making Compliance Training Memorable: Gamechanger 1 – Focus on Strengths

There is not much Tom Fox enjoys more than sitting down with one of the most innovative thinkers in compliance, Carsten Tams, to find out what is on his mind regarding compliance. Tom Fox recently had the opportunity to do so on the topic of making compliance training memorable. Over this short, five-part series, we will introduce the problem and challenges and then provide you with four game-changing strategies you can employ for success in your compliance training.

In this Episode 2, we discuss the concept of focusing on strengths within compliance and ethics training as opposed to traditional deficit-based methods that highlight potential misconduct.

When we instruct people about prohibited behaviors and how the company detects and disciplines misconduct, employees often feel mistrusted and alienated. They tune out. This is deficit-based learning. It approaches the learner as a risk factor or potential delinquent. It aims to constrain unwanted behaviour.

When employees can learn how to effectively shape and safeguard the ethical workplace they aspire to, they feel inspired and tune in. This is strength-based training. It approaches the learner as a valued partner in maintaining integrity.

It assumes that people have capabilities, It aims at eliciting and strengthening the positive ethical faculties already present in most people.

Tom and Carsten urge a shift in perspective so that learners are viewed as valued partners, drawing upon the principles of self-affirmation theory and strength-based approaches found in various sectors like healthcare and education. This approach aims to engage learners by acknowledging and enhancing their capabilities, ethical values, and problem-solving skills, thus fostering a sustainable ethical culture within organizations. Examples of successful applications of this approach, including innovative training methods and programs like UNESCO’s card game and the ‘Giving Voice to Values’ curriculum, are highlighted. The conversation underscores the importance of designing training that not only prevents misconduct but also supports and develops employees’ strengths, thereby enhancing overall company culture.

 Highlights and Key Issues Discussed:

  • The Problem with Deficit-Based Training Approaches
  • The Power of a Strength-Based Approach
  • Real-World Applications and Success Stories
  • Practical Steps Towards Strength-Based Training
  • Building a Sustainable Ethical Culture

Resources:

Carsten Tams on LinkedIn

Emagence Consulting

Tom Fox

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Culture Week: Part 5 – A Listening Tour to Improve Culture

We conclude our focus on culture this week by returning to some of our long-time compliance roots for improving culture, such as the listening tour. In 2022, returning Starbucks Chief Executive Officer (CEO) Howard Schultz began engaging in a “listening tour” of Starbucks stores literally across America. In an article by Justin Bariso, he said Schultz told employees, “We are traveling the country, trying to, with great sensitivity, understand from you how can we do better.” What are employees telling him? Bariso wrote, “he listens intently to one Starbucks employee after another; a pained look comes over Schultz’s face. Employees lament the lack of training, increased turnover, and extreme pressure they’ve endured as company profits soared, but worker conditions plummeted.”

This listening tour has several goals for Schultz. The first is that even though the company has sustained record profits, morale at the company is at an all-time low. Witness the unionizing efforts that have been successful. Employees are simply fed up with not being listened to. This has eroded employee trust and management and driven down the once vibrant culture at the iconic institution. To rebuild that trust, Starbucks, as their CEO, “must first listen.” However, it is more than simply listening to rebuild trust; it is rebuilding employee engagement by making them and their ideas part of the solution.

There is still much work for Starbucks and Schultz to do. Yet these initial steps can lead to real change. Schultz is doing more than saying “We Care”; he is modeling that language in his behavior. This is action at the top. It also communicates to other senior management that they must listen to re-engage and build employee trust. What if a Chief Compliance Officer took that same approach to culture? I believe that a Schulz-inspired listening tour can improve your corporate culture. Below are three keys for the compliance officer to conduct a practical listening tour.

A. Engagement

Start by meeting as many compliance stakeholders as possible. You can use town hall settings or go smaller, meeting with key employee leaders, key stakeholders, and employees identified as high-risk who you can meet with individually or in smaller groups. Listen to their compliance concerns and take their compliance ideas back to the home office. After returning to your office, winnow down their ideas and suggestions to form the basis of enhancements to your culture. This employee engagement will lead to greater stakeholder buy-in for your culture.

B. Education

During the town hall meetings and the smaller, more informal group meetings, you can do more than simply listen—you can also train. This training is on ethics and how the employees could use compliance as a business tool. Most business’s ethical standards are not found in an existing compliance program. They are found in the general anti-discrimination guidelines and ethical business practices such as anti-competitiveness and prohibition of using confidential information. Often, these general concepts can be found in a company’s overall Code of Conduct or similar statement of business ethics. Workplace anti-discrimination and anti-harassment guidelines can be found in Human Resource policies and procedures. Concepts such as anti-competitiveness and the use of customers’ and competitors’ illegally obtained confidential information may be found in antitrust or other business practice-focused guidelines.

This gets your employees and other stakeholders thinking about doing business ethically. It is ethical concept-based training, in contrast to a rules-based approach. Moreover, this lays the groundwork for enhancing your culture and the training that will occur as the enhancement is rolled out.

C. Risk Assessment

Now, think about this same approach from the risk assessment perspective. Listen to your employees’ concerns and compliance issues. From there, you can ask questions about what was done and why. This approach is not adversarial or interrogation, but it is ferreting out the employees’ concerns while having the employees educate your compliance team on the actual procedures that are used. By listening and gently questioning, you should garner enough information to create a risk assessment profile that can inform and even become the basis of compliance program enhancements.

Bariso concluded his article by stating, “People lose motivation when they sense you don’t care. But the simple act of listening creates goodwill. When your people feel understood, they’ll be motivated to contribute and can help you discover insights you wouldn’t otherwise. So, when it comes to solving your company’s biggest problems, don’t ignore your most helpful resource: your people.” It all starts with listening. Let your employees and other stakeholders have the “chance to share their problems, as well as to propose solutions. Meetings like these will reveal key insights and transform your people from employees to partners.”

I hope you have enjoyed and, more importantly, found this week’s blog posts on helpful culture. I also hope you will join the conversation by commenting or posting on LinkedIn about your experiences around corporate culture.

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Blog

Culture Week: Part 2 – Attributes of a Toxic Corporate Culture

We continue our exploration of aspects of corporate culture. Today, we turn to the dark side by reviewing some of the characteristics of a toxic corporate culture. An article in the MIT Sloan Management Review provided some guidance. In Why Every Leader Needs to Worry About Toxic Culture, Donald Sull, Charles Sull, William Cipolli, and Caio Brighenti posited that, by pinpointing the elements of toxic culture in a company, its leaders focus on addressing the issues that lead employees to disengage and quit. These ideas are essential for compliance as they navigate corporate culture and assess and improve it.

Moreover, the Chief Compliance Officer and corporate compliance function were again identified in the 2023 Evaluation of Corporate Compliance Programs (ECCP) as the institutional justice and fairness keepers. This means recognizing and preventing a toxic culture from spreading and infecting your entire organization, which is squarely in the compliance wheelhouse. The article lays out vital red flags for every CCO and compliance professional to look for in assessing culture. Last but not least, for any company with a toxic culture, the likelihood that its employees will commit fraud or bribe and corrupt others by breaking laws like the Foreign Corrupt Practices Act (FCPA) is much higher.

The authors identify behaviors they call “the Toxic Five attributes,” which are being “disrespectful, non-inclusive, unethical, cutthroat, and abusive—poison corporate culture in employees’ eyes. While organizational culture can disappoint employees in many ways, these five elements have by far the largest negative impact on how employees rate their corporate culture and have contributed most to employee attrition throughout the Great Resignation.” As a CCO or compliance professional, you must be on the lookout for them and take steps to remedy them if you see or hear about them.

Disrespectful Behavior

The authors found that “feeling disrespected at work has the largest negative impact on an employee’s overall rating of their corporate culture of any single topic.” Lack of respect can occur in many areas. The most obvious is the lack of a “speak up” culture where employees understand it is useless to raise issues with management, whether serious matters such as FCPA violations or more straightforward ideas such as process improvement. It can also be as simple as whether to return to the office full-time and whether management listens to employees about their desires to continue working from home or to utilize some hybrid working arrangement. The authors noted, “Whether you analyze culture at the level of the individual employee or aggregate to the organization as a whole, respect toward employees rises to the top of the list of cultural elements that matter most.“

Non-inclusive Behavior

This concerns whether your employees are “treated fairly, made to feel welcome, and included in key decisions.” It is “the most powerful predictor of whether employees view their organization’s culture as toxic. It applies to all demographic groups: “gender, race, sexual identity and orientation, disability, and age.” It can be outright discrimination against the equally invidious but more subtle conflicts of interests of nepotism and playing favorites. The topic of non-inclusiveness includes “terms like ‘cliques,’ ‘clubby,‘ or ‘in crowd‘ that indicate that some employees are being excluded without specifying why.“

Ethical Behavior

The authors believe ethics “is a fundamental aspect of culture that matters at both the organizational and individual levels.“ Interestingly, there are several different aspects of “ethics“ that every CCO needs to consider. Unethical behavior is “about integrity and ethics within an organization.“ It also includes dishonesty. “Employees described dishonest behavior in many ways,“ from outright lying to making false promises to shading the truth to simply “sugarcoating.“ Under regulatory compliance, employees talked about failure to comply with applicable regulations, including failure to meet safety standards.

Cutthroat Behavior

I found this category fascinating as it included both uncooperative coworkers and the lack of harmonization across organizational silos. This was not simply “friction in coordination,“ but situations in which “employees talked about colleagues actively undermining one another.“ It included what the authors termed as a “vivid lexicon to describe their workplace, including ‘dog-eat-dog‘ and ‘Darwinian‘ and talked about coworkers who ‘throw one another under the bus,‘ ‘stab each other in the back,‘ or ‘sabotage one another.'”

Abusive Behavior

Having worked in law firms long ago, I understand abusive behavior. The authors called it “sustained hostile behavior toward employees,“ including “bullying, yelling, or shouting at employees, belittling or demeaning subordinates, verbally abusing people, and condescending or talking down to employees.“ While one would hope such behaviors do not exist in the 21st century, they still do. The article’s authors reported that only 0.8% of the employees surveyed described their manager as abusive. However, when employees did mention abusive managers, it significantly depressed the corporate culture.

What CCOs and compliance professionals should try to drive forward is a “culture that is inclusive, respectful, ethical, collaborative, and free from abuse by those in positions of power.“ However, the authors caution that these are the “baseline elements of a healthy corporate culture.“ Employees want more than the basics; other organizational stakeholders want companies to have official, solid core values. In an interview with LRN’s Susan Divers, she called this emphasis on core values the “value in values.” From the compliance professional’s perspective, it means values like integrity, collaboration, respect, and DEI.

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Blog

Culture Week: Part 1 – Redesigning Culture

In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any company in a white-collar criminal investigation, specifically the FCPA. Today, I look at how a company can think through a process to redesign its culture.

How can you think of a different way to redesign your culture and compliance program? This is based on an article in MIT Sloan Management entitled The Four-Step Process for Redesigning Work by Lynda Gratton. Gratton believes a “fear of failure weighs heavily on many leaders tasked with managing new workplace expectations. Seeing the challenge as a process is the way forward.” Her piece provides a great way to consider the future decision to adopt hybrid or other working models.

Moreover, this fear is disrupting other areas that demand corporate attention right now and has left leaders hypersensitive to issues of retention and unsure what accommodations, if any, will attract and keep talent. They are also apprehensive about what their competitors are doing. This has a ripple effect. Because of the fear of failure, I’ve seen leaders begin to stumble on issues of inclusion, belonging, and identity. Rather than being bold and adopting an experimental mindset, they fall back to familiar operating methods and become less empathetic to what others want. When we fear failure, we retreat to the known.

I would only add that the same is true for the corporate compliance function.

In Gratton’s opinion, “Organizations need to undergo a structural overhaul, and more people than just the top leadership of an organization need to work out the task of moving forward.” Leaders who have confronted their fears and set about this task of overhaul have done it by moving through four crucial steps: understanding people, networks, and jobs; reimagining how work gets done; modeling and testing redesign ideas against core principles; and ensuring the overhaul sticks by taking action widely.”

Understand What Matters

The top fear or concern is the decision to work from home or require workers to return to the office. However, the key is “to precisely understand what matters: for example, where and how productive work takes place, what people want, and how knowledge flows.” For instance, being in the office can increase productivity for crucial tasks, particularly when it comes to individual thinking, analyzing, and writing. It turned out that being out of a busy office during lockdown was a plus for these people.

However, that is not the only equation, as “work, people, and knowledge flow differently across companies.” Gratton noted from one study participant, “Bringing ideas from all our disciplines is crucial. We have engineers, designers, planners, technical specialists, and consultants in the office. We want them to talk to each other and bounce ideas off each other.” This leadership clarity allows “an office-based way of working that would maximize highly valued cooperative behavior.”

Reimagine new ways of operating.

Understanding the focus of your compliance team can be a key driver of productivity. Still, it can also lessen “fears about pushing for an office-based way of working and enable them to be imaginative and bold.” For instance, you might create opportunities for some employees to work anywhere for three months. Once again, this might not work for all companies, but if your compliance tasks can lend themselves to this approach, it could be helpful for you to consider it going forward.

The author reported, “Unilever reimagined the employee contract—the set of promises employers make to their people.” To that end, “the conglomerate reimagined how to enable employees to work for Unilever while engaging in other activities such as starting a business, traveling, or caring for a family member. In this model, called U-Work, some employees receive a monthly retainer and earn assignment pay. Importantly, they also get pension support and access to health insurance.” This allows flexibility “between being a full-time employee and being a contractor or agency worker from a third-party organization.”

Model and test new ways of working

Any model work should be aligned with the company’s purpose or business strategy. Unfortunately, that means treating your employees like children in many top-down businesses. But if you succeeded during the pandemic (and you had to), you should be able to determine a hybrid way of working that could have a longer-term impact.

For compliance, that might mean a fuller determination of what “customer-centric means and how hybrid work would have to align with changing customer needs.” Of course, for a compliance professional, your customers could be a variety of stakeholders, such as employees, Supply Chain vendors, or other third parties. The author’s point is to “be bold and courageous in your attempt… in the spirit of being experimental.”

Act and create

An explicit concern is that new work models may become fads that are never really embedded into the company’s culture or will be discarded at the first sign of a recession or cost-cutting. While senior leadership is critical in supporting such initiatives, Gratton identified four ways to deepen engagement and support throughout an organization for such a change.

1. Managers must be engaged. A series of workshops with them helped create a managerial playbook.

2. Communication to describe how these new work models would positively impact talent attraction and retention while supporting the strategic aim of the business.

3. Managers should have open and active communication channels with their teams to reach agreements on details, such as when employees will work together in the office and when they will engage in focused work at home.

4. Managers should support each other through peer networks to support and learn from each other.

Gratton ended her piece by challenging leaders to ask themselves three questions: “Where are you now on redesigning work? Are there steps you need to take to reengage more purposefully? Are you clear about what your biggest priorities are? Your actions will create your signature work model and define the deal you are making with your employees and customers.” The same applies to a Chief Compliance Officer, the corporate compliance function, and culture.

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Great Women in Compliance

Great Women in Compliance: Amy Mertz Brown on Financial and Regulatory Compliance

Welcome to the Great Women in Compliance Podcast!

In this episode, Lisa visits with Amy Mertz Brown, the SVP Chief Compliance and Privacy Officer at BECU.

Amy started her career in the US government, where she was one of the first leaders at the  Consumer Financial Protection Bureau and was formerly the Chief Compliance Officer at the US Securities and Exchange Commission.  She discusses the similarities and differences between her government and in-house regulatory experiences, and the importance of specific training and detailed work instructions in highly regulated industries.

Amy also shares how she has built her career, and what she views as important in deciding on taking on a new role. Amy and Lisa also talk about Reshma Saujani’s views about imposter syndrome, rather than looking at the reasons someone feels like an imposter and questioning the concept and how it impacts women.

Key Highlights:

  • Regulatory Compliance in the Government and in the Private Sector
  • Regulatory Compliance Through Monitoring and Training
  • Navigating Evolving Financial Regulations
  • Questioning the Imposter Syndrome

Join the Great Women in Compliance community on LinkedIn here.

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Compliance Into the Weeds

Compliance into The Weeds: The Complexity of Risk Assessments

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom and Matt take a deep dive into the variables a compliance professional should consider when performing a risk assessment. We also say a few words about our experiences in the total solar eclipse of April 8.

Risk assessments in compliance encompass the careful evaluation of both external and internal risks, necessitating a carefully planned process for overseeing various risk assessments within a company. This task, while intricate and often challenging, is a crucial aspect of compliance.

Fox emphasizes the necessity of precisely defining the scope of risk assessments, which could involve assessing external threats, internal controls, or both. He proposes that companies could benefit from the guidance of internal audits, external consultants, or professional service firms.

Similarly, Matt acknowledges its complex and challenging nature. Kelly underscores the importance of a disciplined, coherent approach to managing risk assessments across different parts of an organization, suggesting the possibility of involving assistance from third-party firms or internal audit teams.

Both Fox and Kelly’s perspectives underscore the importance of strategic planning, effective management, and possible external input in conducting risk assessments in compliance programs.

Key Highlights:

  • Comprehensive Approach to Conducting Risk Assessments
  • Collaborative Risk Assessment for Compliance Optimization
  • Enhancing Compliance through Internal Control Testing
  • Strategic Integration of Compliance in Enterprise Risk
  • Celestial Event Viewing: The Influence of Clouds

Resources:

Matt on Radical Compliance

 Tom 

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 25 – The Never Go Away Edition

What happens when two top compliance commentators get together? They talk about compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode! In this episode, Tom and Kristy tackle various compliance-related topics.

Tesla’s corporate governance is under the spotlight, focusing on the company’s board independence and potential conflicts of interest. Fox has pointed out Elon Musk’s profound control over Tesla, suggesting that the lack of board independence and oversight may necessitate regulatory scrutiny, especially from the Securities and Exchange Commission (SEC). His perspective is rooted in his belief in the importance of corporate governance in protecting shareholder interests, and he raises questions about whether Musk’s leadership is aligned with the expectations of a public company CEO. Similarly, Kristy cites problems with board independence and potential conflicts of interest. She emphasizes the lack of governance within Tesla, particularly noting the court-nullified pay package granted to Musk, and suggests that the SEC may need to intervene even further. She, like Fox, implies that it may be time for Musk to step down and allow for better governance under the scrutiny of regulatory authorities.

Highlights Include

  1. Warren wants the SEC to look into Tesla Board independence. (WSJ)
  2. Goldman files a suit against Malaysia over 1MDB. (Bloomberg)
  3. Mike Lynch finally goes on trial. (FT)
  4. SEC settles first AI washing enforcement. (WSJ)
  5. Adani Green says there is no DOJ investigation notice. (Bloomberg)
  6. TikTok’s Fate Now Hinges on the Senate (WSJ)
  7. The EU Corporate Sustainability Due Diligence Directive—March 2024 Update (JDSUPRA)
  8. Survey: CCO Resources, Pressures Both Rising (Radical Compliance)
  9. Data sharing causing concerns for drivers (WGRZ)
  10. ‘Not my fault the truck don’t surf’: Florida man arrested after driving car into the ocean (WFLA)

Resources

Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom

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