Categories
Great Women in Compliance

Great Women in Compliance – When Women Speak Up: Gender, Whistleblowing and Retaliation

In this roundtable episode of the Great Women in Compliance Podcast, Lisa Fine and Ellen Hunt are joined by whistleblower attorney Mary Inman and Professor Kate Kenny from the University of Galway to explore what really happens when women speak up. Drawing on Professor Kenny’s decade-long research on whistleblowing—including recent work with Transparency International—the conversation examines why women whistleblowers often face greater challenges, which deter them from raising concerns or from deciding to leave a job, rather than speaking up.

The discussion unpacks how gender stereotypes, gaslighting, and organizational culture shape how concerns are received and why women are more likely to speak up when strong protections, anonymity, and collective reporting options are in place. Mary Inman adds a practitioner’s perspective, sharing what she sees in real cases and why many women choose to report together rather than go it alone.

As Ethics and Compliance practitioners consider how to help people speak up, this episode challenges us to review our programs and make improvements to support anyone raising concerns.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 14 – Internal Controls

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. Today, on Day 14, the focus is on internal controls and their critical role in compliance frameworks.

Key highlights:

  • Defining Internal Controls
  • Key Components of Internal Controls
  • Internal Controls in Compliance Programs

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

Categories
Blog

Greek Philosophers Week: Part 3 – Aristotle and the Daily Practice of Ethics & Compliance

In Part 3, we continue our exploration of the origins of the modern corporate compliance organization, tracing them back to the ancient Greek philosophers, including Aristotle. Plato teaches compliance professionals how to design ethical governance systems. But anyone who has ever operated a compliance program knows that structure alone does not guarantee ethical behavior. Policies exist. Committees meet. Reporting lines are drawn. And yet misconduct still occurs. That is where Aristotle becomes essential to the modern compliance conversation.

Aristotle was not interested in ideal societies. He was interested in how people actually behave. His philosophy focuses on habit, judgment, incentives, and purpose, all of which are central to daily compliance operations. The DOJ Evaluation of Corporate Compliance Programs (ECCP) reflects this Aristotelian realism. It asks not only whether a program is well designed, but also whether it is implemented in practice and works in reality.

If Plato is the architect of compliance, Aristotle is its operator.

Virtue as Habit, Not Aspiration

Aristotle rejected the idea that ethics is a matter of knowing the right thing. He argued that virtue is formed through repeated action. People become ethical by practicing ethical behavior until it becomes a habit. This insight aligns directly with the ECCP’s focus on implementation and effectiveness. Prosecutors do not evaluate what a company claims to value. They assess how employees actually behave under pressure. Training, policies, and controls matter only to the extent they shape habits.

In daily compliance work, this means moving beyond episodic interventions. Annual training does not create virtue. Consistent reinforcement does. Indeed, the DOJ specifically called out companies that “have invested in shorter, more targeted training sessions to enable employees to timely identify and raise issues to appropriate compliance, internal audit, or other risk management functions.”

Managers who model ethical decision-making, align incentives with values, and apply consequences fairly all shape behavior over time. Aristotle reminds us that culture is built one decision at a time.

Practical Wisdom and Gray-Area Decision Making

Aristotle distinguished between technical knowledge and phronesis, or practical wisdom. Rules cannot anticipate every situation. Judgment fills the gap. The ECCP implicitly recognizes this by emphasizing risk-based decision-making. A compliance program that relies solely on rigid rules will fail in complex environments. Investigations, third-party reviews, and transaction approvals all require judgment informed by experience and context.

For compliance professionals, this means embracing their role as ethical decision-makers rather than just rule enforcers. It also means documenting judgment. Regulators understand discretion, but they expect it to be principled, consistent, and explainable. Aristotle teaches that wisdom is demonstrated through action guided by reason.

The Golden Mean and Proportional Compliance

One of Aristotle’s most enduring ideas is the Golden Mean. Virtue lies between extremes. Courage sits between recklessness and cowardice. The same principle applies to compliance design and operations. The ECCP expects programs to be appropriately tailored to risk. Over-engineered compliance systems create fatigue, false positives, and cynicism. Under-resourced programs invite misconduct. Both extremes are failures.

Daily compliance operations must strike a balance. Monitoring should be robust but targeted. Controls should be strong but workable. Reporting requirements should capture risk without overwhelming employees. Aristotle reminds us that effectiveness lives in proportion, not excess.

Incentives Reveal Character

Aristotle believed character is revealed by what people pursue and what they are rewarded for achieving. This lesson is painfully relevant to compliance failures. This is also the basis for modern due diligence. The ECCP repeatedly asks how companies incentivize compliance and discipline amid misconduct. The ECCP states, “Another hallmark of effective implementation of a compliance program is the establishment of incentives for compliance and disincentives for non-compliance.” Compensation structures that reward results regardless of method undermine every policy on the books. Employees respond to what is rewarded, not what is written.

In practice, compliance professionals must engage with compensation, promotion, and performance management. Ethics cannot be siloed. When high performers are excused from consequences, the organization sends the message that virtue is optional. Aristotle would argue that such systems inevitably produce unethical outcomes, regardless of stated values.

Purpose and the Role of Compliance

Aristotle believed everything has a telos, an ultimate purpose. Understanding purpose guides action and gives coherence to effort. Compliance programs often struggle when their purpose is framed narrowly as avoiding fines or enforcement. The ECCP encourages companies to adopt a broader perspective, emphasizing risk management, trust, and sustainable operations.

In daily work, purpose shapes priorities. Is compliance positioned as a business partner or a policing function? Is it involved early in decision-making or consulted after damage is done? Aristotle teaches that clarity of purpose aligns behavior. When compliance understands and articulates its role as protecting the organization’s long-term health, its influence grows.

5 Key Takeaways for the Compliance Professional

1. Ethical behavior is formed through habit, not intention.

Aristotle teaches that virtue develops through repeated action. Compliance programs must therefore consistently reinforce ethical behavior, not just episodically. The ECCP emphasizes implementation because policies alone do not shape conduct. Daily reinforcement through leadership behavior, aligned incentives, and consistent consequences builds habits that endure. Compliance professionals should evaluate whether their programs influence how employees actually act under pressure, not just what they acknowledge in training.

2. Judgment is a core compliance competency.

Rules cannot anticipate every scenario. Aristotle’s concept of practical wisdom aligns with the ECCP’s expectation of risk-based decision-making. Compliance professionals must exercise and document judgment in investigations, approvals, and remediation. This requires experience, training, and independence. Ethical compliance is not mechanical. It is reasoned, contextual, and defensible when challenged by regulators or boards.

3. Proportion matters in compliance design.

The Golden Mean teaches that extremes undermine effectiveness. Overly burdensome controls create fatigue and workarounds. Weak controls invite abuse. The ECCP expects tailoring based on risk, geography, and business model. Compliance leaders must design right-sized programs that employees can follow and that management can support. Balance is not compromise. It is effective.

4. Incentives define culture more than policies.

Aristotle understood that character is shaped by what is rewarded. Compliance failures often stem from misaligned incentives. The ECCP scrutinizes compensation and discipline for this reason. Daily compliance operations must engage with HR and leadership to ensure ethics are embedded in performance evaluations, promotions, and bonuses. Culture follows incentives, not slogans.

5. Compliance must have a clear purpose.

Aristotle’s concept of telos reminds us that purpose guides action—compliance programs framed solely as legal defense lose credibility. The ECCP encourages a broader view of compliance as a risk-management and trust-building approach. When compliance professionals articulate their purpose clearly, they gain influence, resources, and early involvement in decisions that matter.

From Aristotle to Pythagoras: From Judgment to Measurement

Aristotle grounds compliance in habit, judgment, and proportion. But judgment alone is not enough in modern organizations operating at scale. As programs mature, leaders ask how to measure effectiveness, detect patterns, and anticipate risk.

That transition leads naturally to Pythagoras. Where Aristotle focuses on ethical action, Pythagoras focuses on number, proportion, and harmony. In compliance terms, this is the shift toward data analytics, metrics, and AI. If Aristotle teaches us how people should behave within ethical systems, Pythagoras teaches us how to observe, measure, and test whether they actually do.

Aristotle teaches us how ethical compliance is lived day to day. Pythagoras will push the conversation further, asking how data, analytics, and AI can measure, test, and strengthen those ethical systems without losing proportion or judgment. Join us tomorrow in Part 4 to find out how.

 

Categories
Innovation in Compliance

Innovation in Compliance – The Strategic Evolution of Compliance: Insights from Angie McPhail

Innovation comes in many forms, and compliance professionals need not only to be ready for it but also to embrace it. Join Tom Fox, the Voice of Compliance, as he visits with top innovative minds, thinkers, and creators in the award-winning Innovation in Compliance podcast. In this episode, host Tom Fox welcomes Angie McPhail to discuss the transformation of compliance from a regulatory function to a strategic business imperative.

Angie shares her professional background, having led the Integrity and Compliance group for the Americas at Juniper Networks before its acquisition by HPE. Key discussions include the evolving role of compliance as a strategic influencer within organizations, the intersection of ethics and integrity with ESG, and the importance of trust in building effective compliance programs. Angie emphasizes the need for compliance professionals to understand business strategy, leverage technology, and build trust to drive sustainable growth. The talk also covers the future outlook for compliance leaders and provides advice on preparing the next generation of compliance professionals.

Key highlights:

  • Compliance as a Strategic Business Function
  • Influence and Trust in Compliance
  • Compliance as a Driver of Business Success
  • Managing Reputational Risk
  • Future of Compliance Leadership

Resources:

Angie McPhail on LinkedIn

Innovation in Compliance was recently ranked 4th among Risk Management podcasts by 1,000,000 Podcasts.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 13 – Policies and Procedures

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. In this Day 13 episode, we review the importance of having well-crafted compliance policies and procedures as the foundation of a robust compliance program.

Key highlights:

  • Importance of Compliance Policies
  • Key Elements of Compliance Policies
  • Assessment and Evolution of Policies

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 12 – The Importance and Construction of a Corporate Code of Conduct

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. This Day 12 episode explores the critical value and construction of a corporate Code of Conduct, explaining its evolution from a legalistic document to a cornerstone of compliance programs.

Key highlights:

  • Introduction to Code of Conduct
  • Regulatory Expectations and Guidelines
  • Crafting an Effective Code of Conduct

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

Categories
Blog

Greek Philosophers Week: Part 1 – Socrates and the Asking Questions

I have long wanted to trace the origins of the modern corporate compliance organization back to the ancient Greek philosophers, drawing lessons for compliance and ethics in 2026 and beyond. Today, I begin a five-part series where I do just that. In this series, we will consider Socrates, Plato, Aristotle, Pythagoras, and Euclid. We start with Socrates.

Socrates left no writings of his own. What he left was a method. He believed wisdom began with recognizing what one did not know and then relentlessly testing assumptions through disciplined questioning. That approach maps directly onto the daily work of the compliance professional. Risk assessments, investigations, root cause analysis, culture reviews, and even board reporting all rise or fall based on the quality of the questions asked.

Every effective compliance program begins with a question. Not a policy. Not a control. Not a dashboard. A question. That insight alone makes Socrates the right place to start any serious discussion about the influence of ancient Greek philosophy on modern corporate compliance and ethics programs.

The Department of Justice’s Evaluation of Corporate Compliance Programs (ECCP) does not use the word “Socratic,” but its expectations are unmistakably aligned with Socratic inquiry. Prosecutors repeatedly ask whether a company understands its risks, tests its assumptions, challenges its controls, and adapts when reality changes. A compliance program that does not ask hard questions is not mature. It is merely quiet. Indeed, Hui Chen, the author of the original ECCP, has said that a key purpose of the ECCP was to get compliance professionals to ‘ask questions’.

Ethical Inquiry as a Compliance Obligation

Socrates believed that unexamined beliefs were dangerous. He challenged Athenian leaders not because he enjoyed disruption, but because false confidence creates harm. In a corporate setting, the same risk exists when executives assume that a policy equals compliance or that training completion equals ethical behavior.

  1. Is the corporation’s compliance program well designed?
  2. Is the program being applied earnestly and in good faith? In other words, is the program adequately resourced and empowered to function effectively?
  3. Does the corporation’s compliance program work in practice?

These questions are fundamentally Socratic. It demands inquiry into how the business actually operates, where pressure points exist, and how misconduct could realistically occur. A compliance function that accepts management narratives at face value fails this test.

Daily compliance operations depend on this discipline. When reviewing third-party relationships, a Socratic compliance officer does not ask whether due diligence was performed. They ask whether it was sufficient, whether red flags were rationalized, and whether business incentives distorted judgment. That is inquiry, not administration.

Challenging Assumptions Without Becoming the Enemy

Socrates was executed because his questioning made powerful people uncomfortable. Compliance professionals face a less dramatic, but no less real, version of that tension. The role requires challenging assumptions, even when doing so slows deals, complicates reporting lines, or disrupts revenue projections.

The ECCP specifically evaluates whether a corporate compliance function has sufficient staff to audit, document, analyze, and utilize the results of the corporation’s compliance efforts. Prosecutors should also determine “whether the corporation’s employees are adequately informed about the compliance program and are convinced of the corporation’s commitment to it. Does the company’s culture of compliance, including awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated.”

Those structural questions exist because DOJ understands that inquiry without protection is performative. If compliance professionals cannot safely ask uncomfortable questions, the program is cosmetic.

In daily operations, this plays out in subtle ways. Does compliance have the authority to pause a transaction? Can investigators follow evidence wherever it leads? Are audit findings welcomed or explained away? A Socratic approach demands that compliance leaders test these realities rather than assume the answer.

The Socratic Method in Investigations and Root Cause Analysis

Socrates did not accept the first answer offered. He pushed deeper, often exposing contradictions or incomplete reasoning. That approach is directly applicable to investigations and root cause analysis. The ECCP places significant emphasis on whether companies understand why misconduct occurred and whether remediation addresses underlying causes. Too many investigations stop at identifying who violated a policy. Echoing Jonathan Marks, Socratic investigation asks why the violation made sense to the individual at the time. What pressures existed? What incentives misaligned behavior? What controls failed or were bypassed?

This type of inquiry requires patience and courage. It also involves trust from leadership. Findings may implicate management decisions, cultural signals, or compensation structures. Socrates reminds us that truth-seeking is rarely comfortable, but it is essential to ethical improvement.

Culture Is Revealed by the Questions You Allow

Socrates believed that a society’s health could be measured by its openness to questioning. The same is true for corporate culture. The questions employees feel safe asking reveal more than any values statement. The ECCP now explicitly asks companies to explain how they measure and address culture. The ECCP states, “Prosecutors should also assess how the company has leveraged its data to gain insights into the effectiveness of its compliance program and otherwise sought to promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.” Surveys, hotline data, and exit interviews are tools, but they are meaningless without inquiry. Key questions include: Are employees encouraged to speak up? Are concerns investigated thoroughly? Are outcomes communicated? Is retaliation punished?

In daily compliance practice, this means listening as much as enforcing. A Socratic compliance program does not treat employee concerns as noise to be managed. It treats them as data points to be explored. The quality of questions asked in response to a report often determines whether trust is strengthened or destroyed.

5 Key Takeaways for the Compliance Professional

1. Effective compliance begins with inquiry, not documentation.

A compliance program does not become effective simply because policies exist or training is completed. Effectiveness begins when compliance professionals consistently ask how misconduct could realistically occur within their organization. This requires challenging business assumptions, pressure points, and incentive structures. The ECCP repeatedly emphasizes the importance of understanding risk in context, which is impossible without disciplined questioning. A Socratic approach positions inquiry as an operational obligation, not an intellectual exercise, ensuring the program remains dynamic, responsive, and grounded in reality rather than formalism.

2. Risk assessments are living Socratic exercises, not static reports.

Too many organizations treat risk assessments as periodic documentation rather than ongoing inquiry. A Socratic risk assessment tests assumptions continuously as business models, geographies, and incentives evolve. Compliance professionals should revisit risk hypotheses, ask whether controls still function as intended, and challenge comfort-driven conclusions. Under the ECCP, regulators expect risk assessments to inform program design and resource allocation. Socratic inquiry ensures risk assessments remain relevant, credible, and capable of identifying emerging threats before they mature into enforcement issues.

3. Investigations must pursue understanding, not merely attribution.

Identifying who violated a policy is rarely sufficient to prevent recurrence. A Socratic investigation asks why the misconduct occurred, what pressures or incentives influenced behavior, and how organizational systems failed. This aligns directly with the ECCP’s focus on root cause analysis and remediation. When compliance professionals ask deeper questions, investigations become tools for program improvement rather than disciplinary endpoints. This approach strengthens controls, enhances credibility with regulators, and reduces the likelihood of repeat misconduct driven by unresolved systemic weaknesses.

4. Speak-up culture is defined by response quality, not hotline volume.

Organizations often measure speak-up culture by the number of reports received, but Socrates teaches that the real measure lies in how questions are received and addressed. Employees quickly learn whether raising concerns leads to thoughtful inquiry or defensive dismissal. The ECCP evaluates whether companies encourage reporting, protect against retaliation, and communicate outcomes appropriately. A Socratic compliance function listens carefully, asks clarifying questions, and treats concerns as signals worth examining. That discipline builds trust and reinforces ethical accountability across the organization.

5. Socratic questioning requires independence, authority, and protection.

Inquiry without authority is performative. Socrates paid the ultimate price for challenging power, but modern compliance professionals should not. The ECCP explicitly assesses whether compliance functions have sufficient independence, resources, and access to leadership. Without these safeguards, difficult questions go unasked or unanswered. A Socratic compliance program empowers professionals to challenge decisions, pause transactions, and escalate concerns without fear of retaliation. That structural support transforms ethical inquiry from individual courage into institutional practice.

From Socrates to Plato: From Inquiry to Structure

Socrates gives us the starting point. He teaches the compliance professional how to think, question, and resist complacency. But inquiry alone is not enough. Questions must eventually lead to structure, governance, and systems that translate insight into action.

That transition sets the stage for Plato. Where Socrates focuses on method, Plato focuses on design. The movement from Socrates to Plato mirrors the evolution of a compliance program itself, from asking whether risks exist to building governance structures capable of addressing them. In that sense, Socrates is the conscience of the compliance function. He reminds us that effectiveness begins with intellectual honesty and ethical curiosity. Without those traits, even the most sophisticated compliance architecture will rest on shaky ground.

Join us tomorrow for Part 2 and learn about Plato’s role in today’s compliance and ethics programs.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 11 – Moving Compliance Down into an Organization

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. In this episode, Day 11, we discuss the importance of embedding a culture of compliance throughout all levels of an organization.

Key highlights:

  • Embedding Compliance Culture
  • Role of Middle Management
  • Tone at the Bottom

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 10 – Leadership’s Role in Shaping Corporate Culture and Compliance

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. In today’s episode, Day 10, we dive into the critical role of senior management in fostering a strong corporate culture of compliance.

Key highlights:

  • The Importance of Corporate Culture
  • DOJ’s Expectations for Senior Management
  • Five Factors for Effective Leadership

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.

Categories
31 Days to More Effective Compliance Programs

31 Days to a More Effective Compliance Program: Day 9 – Continuous Monitoring and Continuous Improvement

Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no cost to help update your compliance program. I hope you will join each day in January for this exploration of best practices in compliance. Today, Day 9, we discuss continuous monitoring and continuous improvement.

Key highlights:

  • Understanding Changes in Company Risks
  • Continuous Monitoring and Improvement
  • External Information Sources for Compliance

Resources:

Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 6th edition, by clicking here.