Tag: compliance

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Great Women in Compliance

GWIC x The Ethics Experts-Mary’s Episode

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.

For the next two weeks, the GWIC team are presenting a collab with ComplianceLine: GWIC X The Ethics Experts! Mary and Lisa start their throwback Wednesday sessions by harking all the way back to the early days of COVID19, where Mary’s episode was recorded while she was in the New Zealand coronavirus lockdown.

Gio Gallo interviewed Mary about her leadership style – especially focused on giving (junior) staff substantive, meaningful work and wings to fly while setting out a safety net, how not to slip into complacency in your Compliance program by being reassured of historical achievements, and understanding that there is no lowest common denominator. Learn how you can use surveys to tap into your most vulnerable areas you don’t even know you have.

 Check out Lisa’s interview on the Ethics Experts here on the Great Women in Compliance Podcast on 19 October!

 On 26 October, Mary and Lisa will return to their regular programming with a joint episode on learnings, insights, and observations from the Society of Corporate Compliance and Ethics Compliance and Ethics Institute. Want to be a part of the fun? Introduce yourself to Lisa and Mary at the conference – you’ll be able to spot them by their GWIC tote bags that Lisa kindly procured for the duo.

The Great Women in Compliance podcast is excited to look at topics like this one, and we are always open to suggestions for guests.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings. If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it. If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.

You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast. Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.

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.

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Blog

Ongoing Compliance Assessments: FCPA, UK Bribery Act and OCED Best Practices

One of the requirements consistent throughout the Principles of Federal Prosecution of Business Organization (US Sentencing Guidelines) and its section on corporate compliance programs; the Organization for Economic Co-operation and Development (OECD) Good Practice Guidance on Internal Controls, Ethics, and Compliance, and the UK Bribery Act’s Consultative Guidance is the need for continued assessment of an anti-corruption and anti-bribery compliance program. This posting will review the specifics of each of these documents and will provide to the compliance and ethics practitioner some ideas on how to implement what each of these protocols stress is key component of any best practices compliance program.

US Sentencing Guidelines

The US Sentencing Guidelines state that there should be periodic reviews of a company’s compliance program, utilizing internal resources, such as a company’s Internal Audit function, and outside professional consultants. The OECD Good Practice states that a compliance program should be periodically re-assessed and re-evaluated to take into account any new developments. The UK Bribery Act Consultative Guidance, recently released by the UK Ministry of Justice, requires ongoing monitoring and review by noting that a compliance program and procedures should be reviewed regularly and a company should consider whether an “external verification [of the compliance program] would help.”

Speaking at the Compliance Week 2010 Annual Conference, Assistant Attorney General for the Criminal Division of the US Department of Justice, Lanny Breuer, indicated that such an external verification or assurance of the effectiveness of a compliance program is a key component to assist a company in maintaining a ‘best practices’ FCPA compliance program. He noted that it is through a mechanism such as an ongoing assessment that a company could continue to evaluate its own compliance program with reference to compliance standards which are evolving on a world wide basis.

OECD

In this same speech, Breuer cited as a benchmark for a best practices compliance and ethics program the protocols set forth in the OECD Good Practice Guidance on Internal Controls, Ethics, and Compliance. In this protocol the OECD suggested that “periodic reviews of the ethics and compliance programs or measures, designed to evaluate and improve their effectiveness in preventing and detecting foreign bribery, taking into account relevant developments in the field, and evolving international and industry standards.” Writing in the Society of Corporate Compliance and Ethics Magazine (SCCE) (Vol. 7 / No. 3), Russ Berland explained that this guidance meant that companies should regularly reassess their anti-bribery and anti-corruption compliance program to evaluate and improve its overall effectiveness. Although he did not give a time frame for this regular assessment, Berland noted that any such assessment “should take into account new developments in the area and evolving standards.

UK Bribery Act 

Principle Six of the UK Bribery Act’s Consultation Guidance discusses the need for ongoing monitoring and review. The Principle states “The commercial organization institutes monitoring and review mechanisms to ensure compliance with relevant policies and procedures and identifies any issues as they arise. The organization implements improvements where appropriate.” The reasons for this continued monitoring was to ensure that if, external events like government changes, corruption convictions, or negative press reports occur, an appropriate compliance response is triggered. The Guidance noted that it would be prudent for companies to consult the publications of relevant trade bodies or regulators that could highlight examples of good or bad practice. Organizations should also ensure that their procedures take account of external methods of issue identification and reporting as a result of the statutory requirements applying to their supporting institutions, for example money laundering regulations reporting by accountants and solicitors.

The Consultative Guidance provided advice for companies which covered several specific suggestions. The senior management of higher risk and larger organizations may wish to consider whether to commission external verification or assurance of the effectiveness of anti-bribery and anti-corruption policies. An independent review can provide to a company, which is undergoing structural change or entering new markets, with an insight into the strengths and weaknesses of its anti-bribery policies and procedures and in identifying areas for improvement. Such independent assessment would also enhance a company’s credibility with business partners or to restore market confidence following the discovery of a bribery incident, to help meet the requirements of both voluntary or industry initiatives and any future pre-qualification requirements.

Ongoing Assessment as ‘Best Practices’ 

All three cornerstones of guidance available to the Foreign Corrupt Practices Act (FCPA) compliance practitioner include ongoing assessments as a key component of any best practices program. The text of each document and the remarks by commentators make clear the reasons for such an ongoing assessment. Not only do best practices evolve but companies and business evolve. An assessment is key to measuring where your program currently stands to allow you to know where it needs to be updated.

Attention should be paid to who and how the assessment is conducted. The entity, be it a law firm; professional consultant or other, which designed the FCPA compliance program for your company should not be the assessor. Such assessment would obviously be a conflict of interest. Additionally a drafter usually has blind spots when assessing one’s own work. An outside FCPA compliance professional should be engaged to assess your compliance policy, at no less than every two years, to review and make recommendations to keep your program at the best practices standard.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

 

© Thomas R. Fox, 2010

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Innovation in Compliance

Innovating Compliance in the Middle East and Africa with Tomell Ceasar

 

Tomell Ceasar is the Group Head of Ethics and Compliance at Careem (An Uber Company). He is one of the founders of the Middle East and Africa Compliance Association (MEACA). This organization strives to raise awareness on business ethics and provides tools to build stronger and more responsible businesses. Essentially, they promote global regulatory compliance and effective governance in the Middle East and Africa. In this week’s episode, he explains to Tom the intricacies of practicing compliance outside the US, specifically the EAME. 

 

 

Compliance Practice in the EAME

Tom asks Tomell to describe what it is like practicing compliance in EAME. Tomell responds that it’s difficult to make broad generalizations on compliance region-wide since the EAME is such a huge territory. Compliance is a “Western value in terms of the way one approaches international business”, Tomell remarks, so adoption would take some time. However, appreciation of compliance roles and professionals grew exponentially over the past decade. International companies are seeing compliance through the US lens, and “they identified values of compliance being important enough to them to adopt similar frameworks and ideological perspectives as it relates to commercial enterprise, to be equivalent to the United States,” Tomell remarks.

 

The Birth of the MEACA 

As a co-founder of the Middle East and Africa Compliance Association, Tom wants to know how Tomell came up with the idea for the MEACA. Tomell explains that “the values of compliance have traditionally not been a staple of commercial enterprises in these regions.” Compliance has had a real maturation process over the last 10 years, and Tomell and his team saw a major opportunity to support the development and growth towards that end. There was a need for an organization willing to serve the distinct purpose of “serving and supporting the compliance community and to give them an avenue to connect, to network, to broaden their skill set.” Thus, the MEACA was born. To this day, they help companies promote and catalyze the compliance movement toward fighting corruption in companies and society. 

 

Resources 

Tomell Ceasar | LinkedIn

The Middle East and Africa Compliance Association

 

Categories
Blog

Use Your Eyes in Compliance

One thing compliance professionals are rarely trained to do is trust your eyes. This may be because it seems too obvious. After all the well-known Howard Sklar maxim of “Water is Wet” is largely based on the fact that if something is so obvious you may not need to train on it. Yet two recent events make clear we all need to ‘trust our eyes’ in a variety of settings. The first is in the National Football League (NFL) and it involves Miami Dolphin quarterback, Tua Tagovailoa. Three weeks ago, he was tackled, thrown to the ground and his head snapped against the tuft. This is clearly a sign a concussion may be coming. After Tua got up, he stumbled and fell and then had to be helped up by a teammate and off the field.

I say all of this with absolute certainty as I was watching the game Dolphins v. Bills and saw it along with some 70,000 in the stadium and millions on television. Unfortunately, those who did not see these actions of Tua after the hit was the Dolphins medical staff who, rather amazingly (or perhaps not), cleared him under the NFL Concussion Protocol and sent him back to play in the second half of the game. Again, finding he was fine under the concussion protocol, he was allowed to play. The Dolphins claimed that he had sustained a “back injury” and that was why he stumbled and fell, not motor impairment. The next week, Tua took another shot to his head and this time he did not get up, stumble and fall. He did not get up at all. According to New York Times (NYT), he left the field on a stretcher and was taken immediately to a local hospital.

It was clear to anyone who saw the first concussion, that it was just that a concussion. However, “because of the incident, the league and union said they were considering changing the protocols, which currently allow a player with “gross motor instability” to return to the game if doctors decide there is an orthopedic reason for his unsteadiness.” Some doctor said the instability was due to Tua’s bad back and that was good enough. The NYT went on to further note, “The expected change will be to instead establish ataxia, a term describing impaired balance or coordination caused by damage to the brain or nerves, as a sign that automatically disqualifies a player from returning to the game.”

All of this informs compliance programs and compliance professionals as sometimes actions do not simply pass the eye test. I thought of this in the context of the recent Oracle Corporation Foreign Corrupt Practices Act (FCPA) enforcement action. In this Oracle matter, the bribery schemes involved distributors, which were used as not only conduits to pay bribes, but as the mechanism to create a pot of money to pay bribes. The Oracle compliance program allowed sales employees at the subsidiaries to request monies meant to reimburse distributors for certain marketing expenses associated with selling Oracle products. There was a multi-pronged approval process in place. For marketing reimbursements “under $5,000, first-level supervisors at the Subsidiaries could approve the purchase order requests without any corroborating documentation indicating that the marketing activity actually took place.” Above this $5,000 threshold, additional approvals were required with additional requirements for business justification and documentation.

You can no doubt see where this is going as this internal control gap allowed for abuse. Indeed the Orderstated, “Oracle Turkey sales employees opened purchase orders totaling approximately $115,200 to [distributors] in 2018 that were ostensibly for marketing purposes and were individually under this $5,000 threshold.” That is at least 23 different expense requests to reimburse for marketing made under the threshold. Of course, there were no marketing efforts by the distributors and no follows up audits, inspections or even questions to confirm that the marketing expenses had actually occurred. The entire business unit was in on the fraud, and it stole money from the corporate office to fund it slush fund to pay bribes.

Clearly compliance was not using its eyes for if it had, it would have seen that there was a large number of marketing reimbursement requests at or below the threshold which required additional oversight and approval. Using your eyes does not mean that it is simply your eyes which catch nefarious conduct, it means that you use your eyes and if it something unusual occurs then additional investigation is warranted.

All of this brings to the second lesson from the NFL’s sordid tale involving Tua Tagovailoa; which is if the protocol does not work, change the protocol. Renee Miller, writing The Athletic, said, “The purpose of the onsite concussion “exam is to determine if any symptoms are apparent in a neurological exam (looking at reflexes, cranial nerve function and limited cognitive skills), and if so, whether they arise from a neurological origin.” It does not take into account what we all saw with our eyes, the stumbling, Tua grabbing his helmet and inability to focus. The NFL will now make a change to consider the other factors Tua exhibited. In other words, they changed the protocol to require and allow for additional information about the injured player in making a determination of that player’s returning to the game.

In the case of Oracle, there was a high risk of business unit employees using the marketing reimbursement requests to create a pot of money to pay bribes. We know this because this same bribery scheme was used by Oracle India to pay bribes and do business corruption, all of which was the subject of a prior FCPA enforcement action. Pretty clearly allowing business unit employees to obtain marketing reimbursements was something that would lead to disaster; which it did just as the Dolphins allowing Tua to come back into the second half of the Bills game where he sustained his first concussion was disastrous for Tua as he was much more seriously injured just the next week.

In compliance never forget to ‘use your eyes’ in testing your compliance program. If something does not look right, do additional investigation. If you do not do so, you may end up like Oracle, now one of 15 FCPA recidivists, a list no company wants to be on.

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Corruption, Crime and Compliance

Episode 249 – DOJ Issues New Corporate Enforcement Policy

The Biden Administration promised a new, aggressive approach to corporate crime. Well, the Justice Department just delivered a new, comprehensive policy that raises a number of issues, some of which are likely to be controversial. The new policy incorporates reforms announced last October that largely centered on prior corporate criminal and civil records, the appointment of independent compliance monitors, and expanding the review of responsible persons in an internal investigation. The Justice Department’s new Corporate Enforcement Policy (“CEP”), however, expands on earlier policy changes but includes some new and far-reaching reforms intended to increase individual accountability and promote corporate culture through financial incentives and deterrence policies. This last idea is a significant expansion of DOJ’s CEP and is sure to reverberate through the business and compliance community. Chief compliance officers face a new requirement for their companies — creating an effective system of carrots and sticks to punish misconduct and increase rewards for ethical behavior.DOJ’s new CEP also lays the groundwork for further consideration of corporate responsibility for preserving electronic messaging, ephemeral services, and other electronic data. DOJ’s discussion in this area reflects DOJ’s frustration with a corporate internal investigation that omits access to electronic data, especially in those situations where employees use personal devices for business-related communications. The revised CEP provides guidance to prosecutors and the business community to ensure individual and corporate accountability through the evaluation of various factors, including (1) Corporate History of Misconduct; (2) Self-Disclosure and Cooperation; (3) the Strength of a Company’s Compliance Program; (4) the Use and Monitoring of Corporate Monitors (including their selection and scope of a monitor’s work).

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Blog

Oracle: FCPA Recidivist Part 5 – What Does It All Mean?

In this post, we conclude our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving the now recidivist Oracle Corporation. This enforcement action was concluded with the Securities and Exchange Commission (SEC) resulting in an Order. After having examined the background facts and bribery schemes in some details, we turn to what does it all mean for FCPA enforcement going forward and what lessons can the compliance profession draw from Oracle’s missteps.

Paper Programs Fail

One of the most prominent lessons to be garnered from this matter is that paper compliance programs Do Not Work. That may sound like perhaps the most basic truism in all of compliance but here we are in 2022, looking at a major multinational organization which had a ‘check-the-box’ compliance program around distributors and it eventually bit them in the backside.

After having its first FCPA enforcement action in 2012 involving distributors in India, where deep and unwarranted discounts were used to create a pot of slush funds to pay bribes, Oracle instituted a requirement for a ‘second set of eyes’ outside the business unit for unusual or excessive discounts. According to its policies regarding distributors, a valid and legitimate business reason was required to provide a discount to a distributor. Oracle used a three-tier system for approving discount requests above designated amounts, depending on the product. In the first level, Oracle at times allowed subsidiary employees to obtain approval from an approver in a subsidiary other than that of the employee seeking the discount. At the next level and for higher level of discounts, Oracle required the subsidiary employee to obtain approval from another geographic region and the final level (and for the highest discounts) was from someone at the Oracle corporate headquarters. So far so good.

The problem was there was no requirement for evidence of a business justification to support the requested discount. The Order noted, “Oracle reviewers could request documentary support, Oracle policy did not require documentary support for the requested discounts – even at the highest level.” A statement of why you need a discount without any supporting documents as evidence is simply that – a statement. In other words, there was no way for a higher-level approver to determine if such a request was valid or fraudulent. Ronald Reagan was on to a basic compliance concept when he intoned “Trust, but verify.” Those words still ring true as a basic requirement in any compliance program.

Data Analytics

The Oracle enforcement action emphasized why data analytics is mandatory for any current compliance program. In addition to creating slush funds through discounts to distributors, slush funds were created through fraudulent reimbursement requests for expenses associated with marketing Oracle’s products. If the request were under $5,000, business unit level supervisors at the subsidiaries could approve them without any corroborating documentation indicating that the marketing activity actually took place. In one example from the Order, it noted that an Oracle Turkey sales employees obtained such fraudulent reimbursements totaling approximately $115,200 in 2018 that were “ostensibly for marketing purposes and were individually under this $5,000 threshold.” There was apparently no one looking to see who and how often these reimbursement requests were made by any single employee or approved by any supervisor.

This is as basic a fraud scheme as one can imagine. Think of employee gift, travel and entertainment (GTE) reimbursement where anything over $100 must be preapproved. One BD type or one business unit routinely submits requests after purchases of $99.99 so no preapproval is required. The supervisor approves it, and it is automatically paid to the employee. One reimbursement at $99.99 may not raise a red flag but multiple requests should. The same concept holds true in this situation. However, no one at Oracle was looking at this bigger picture. This is where a data analytics program would pick up such anomalies and flag it for closer inspection and investigation. Oracle appears to have realized this through part of its remediation which included the implementation of a compliance data analytics program moving to proactive auditing.

Internal Control Upgrades

Putting in compliance enhancements to remediate your control failures is a key part to any FCPA enforcement resolution. In this area, there were improvements in the following capacities: (a) in distributor discounting by improving aspects of the Oracle discount approval process and increasing transparency in the product discounting process through the implementation and expansion of transactional controls; (b) in the Oracle procurement process through the increased oversight of, and controls on, the purchase requisition approval process; (c) by the removal of perverse incentives by limiting financial motivations and business courtesies available to third parties; (d) in basic gifts, travel and entertainment policies (GTE) by improving its customer registration and payment checking processes in connection with Oracle technology conferences.

Basic GTE

I cannot believe that in 2022 we are talking about companies that still do not have the most basic GTE policies in force. Since at least 2007, the Department of Justice (DOJ) made clear what was appropriate in business travel, business courtesies and business entertainment. Oracle’s 112 Project decidedly was not as it was designed to appear as a business trip to Oracle’s home office (then in California) related to Oracle’s bid on a project. However, the trip was designed to be a sham to hide boondoggle travel for four government officials. The alleged business meeting at the corporate headquarters lasted only 15 minutes and for the rest of the week, the Oracle BD folks entertained the government officials in Los Angeles and Napa Valley and then took them to a “theme park” in the greater Los Angeles area. Any travel involving government officials or any other covered persons under the FCPA should be submitted to and approved by your compliance function, including costs and the itinerary.

There was much to consider from the SEC enforcement action under the FCPA involving Oracle. We still have not heard from the DOJ. There may be more to come….

Categories
Role of the Board of Compliance

Caremark

Tom Fox and Jonathan T. Marks kick off the series with a deep dive into the 1996 Caremark decision, the 2006 Stone v. Ritter resolution, and the compliance lessons companies and board members can learn from the facts and patterns of these fundamental cases.

▶️ Caremark with Tom Fox and Jonathan T. Marks

Key points discussed in the episode:

  1. Tom Fox gives a brief background on the Caremark case.
  2. Jonathan T. Marks describes how ethical behavior is the backbone of an organization and how this case defined the importance of having proper oversight monitoring.
  3. Tom Fox lays out Caremark’s penalties. He describes the Stone v. Ritter facts, how the bank was sued for failure to perform due diligence on fraudulent investors and violating the Bank Secrecy Act. These schemes follow a pattern that has been seen repeatedly. It has also defined the duties of board members: avoiding negligence and arising from failures.
  4. Jonathan T. Marks explains how fundamentals made their way into compliance laws in other countries, how guidelines are warning shots for companies to clean up, and urging companies to step up.
  5. The Caremark doctrine later refined two conditions for director liability and emphasized why boards must actively engage in oversight.
  6. Board members must get down to the nitty-gritty of what is truly happening in their organizations, ask tough questions, do a deeper self-assessment, and stop refusing to avoid problems and the ugly truth.

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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.

Categories
Corruption, Crime and Compliance

Episode 248 – Deep Dive into the GOL Brazil FCPA Settlement

The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement (“DPA”) with the DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL agreed to pay law enforcement authorities in Brazil to resolve charges in Brazil. In a separate resolution, GOL agreed to pay the SEC $24.5 million over two years. The SEC’s initial settlement calculation was for $70 million, but it was reduced to $24.5 million based on GOL’s financial condition. Michael Volkov reviews the DOJ and SEC FCPA settlement actions in this episode.

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FCPA Compliance Report

Matt Kelly on the Monaco Memo

In this special 5 part podcast series, I am deeply diving into the Monaco Memo and analyzing it from various angles. In this episode of the FCPA Compliance Report, I am joined by my Compliance into the Weeds co-host Matt Kelly for a deep dive into the weeds of the Monaco Memo. Some of the highlights include:

  1. Corporate accountability.
  2. Timeliness in turning over evidence of wrongdoing.
  3. Baby Carrots in evaluating the corporate history of misconduct.
  4. Additions to Evaluation of Corporate Compliance Programs.
  5. Tweaks to the Yates Memo formulation.
  6. Monitors and Monitorships.

 Resources

Matt in Radical Compliance

Tom in the FCPA Compliance and Ethics Blog

  1. Introduction
  2. Self-Disclosure
  3. Corporate Compliance Programs
  4. Monitors
  5. What it all means

Monaco Memo

Categories
Great Women in Compliance

Margarita Derelanko – She’s Going Places

Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.

In late 2018, Mary and Lisa began advertising the launch of the Great Women in Compliance podcast, which would air on 6 December 2018.  Margarita Derelanko was one of the people who saw the marketing collateral and grew excited about the incoming podcast.  She affords Lisa and Mary the opportunity to hear what the launch of the podcast was like from the other side of the fence – the to-date missing aspect of their origin story – what the listenership was thinking and how the podcast was received.  Margarita shares how the podcast has impacted her life, including her takeaways from having her first article published, and the benefits she has gained from the encouragement of the hosts and guests.

Unlike many of the GWIC and certainly unlike Mary and Lisa, Margarita had the opportunity to choose whether or not to be in Compliance and she shares what it’s like for the new generation to consider joining the field – spoiler alert, Compliance Destiny appears yet again!  It’s a real thing folks!

Margarita shares some advice for helping to overcome biases when you don’t look like you fit the part.  She is of very small stature and is lucky enough to have youthful looks – causing some to make unfair judgments.  Listen in for how she overcomes the biases and consider how you can turn some of your perceived greatest weaknesses into a strength.

Following on from Mia Reini’s tips for putting together an engaging line up for the The Home Depot’s Compliance Summit, Margarita lends some tips from her experience on the planning team for the Waud Capital Partner’s Compliance Symposium to have a successful event.

The Great Women in Compliance Podcast is on the Compliance Podcast Network with a selection of other Compliance related offerings.  If you are enjoying this episode, please rate it on your preferred podcast player to help other likeminded Ethics and Compliance professionals find it.  If you have a moment to leave a review at the same time, Mary and Lisa would be so grateful.

You can also find the GWIC podcast on Corporate Compliance Insights where Lisa and Mary have a landing page with additional information about them and the story of the podcast.  Corporate Compliance Insights is a much-appreciated sponsor and supporter of GWIC, including affiliate organization CCI Press publishing the related book; “Sending the Elevator Back Down, What We’ve Learned from Great Women in Compliance” (CCI Press, 2020). If you enjoyed the book, the GWIC team would be very grateful if you would consider rating it on Goodreads and Amazon and leaving a short review.

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.