In today’s edition of Sunday Book Review:
As the NY Mets have the best record in baseball and we prepare for the celebrations of Easter and Passover, Tom and Jay are back to look at some of the week’s top compliance and ethics stories in the Ng Convicted edition.
Stories
Podcasts and More
Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
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. This week, Matt and Tom take on the strange comings and goings of Elon Musk and his participation on the Twitter Board of Directors. Highlights include:
· When and how did Musk become Twitter’s largest shareholder?
· Why was he asked to come on to the Board?
· SEC filing requirement issues?
· What role did the various stakeholder groups, including employees, have in Musk turning down the Twitter Board seat?
· What are the compliance and governance issues to be learned?
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Susan Divers, currently Director of Thought Leadership at LRN.
In 1994, Susan moved in-house becoming the first Deputy GC for international at SAIC. In this role she set up compliance programs for ABC, trade controls and investigations as SAIC did not have a dedicated CECO at that time. She traveled extensively internationally and had experience with the Overseas Private Investment Company after the SAIC joint venture was nationalized by Chavez in Venezuela. After a brief stop at Lockheed Martin, Susan moved to the Chief Ethics and Compliance (CECO) role at AECOM.
Resources
Susan Divers LinkedIn Profile
Andy Rudin is the Managing Principal of Contrary Domino, a management consulting company that improves financial performance by optimizing internal operations. Tom Fox welcomes him to this week’s show to talk about revenue risk management and revenue governance, and what they mean for the sales officers within organizations.
Contrary Domino
Risk management is not often factored in the sales and marketing funnels of organizations. Andy founded Contrary Domino to answer this need. The percentage and likelihood of revenue opportunities closing or coming to fruition aren’t often thought of as risk management problems. “I saw that opportunity and wanted to bring more process rigor to that, more mathematical rigor and bring the risk management principles into the realm of revenue generation,” he tells Tom. Contrary Domino’s client base is mainly information technology firms with sales forces of ten or more. “Helping organizations establish that culture and then establish processes and mechanisms to prevent ethical problems from occurring or at least minimizing their likelihood is central to what I do,” Andy says.
Revenue Risk Management
Tom asks Andy to define revenue risk management. “Revenue risk management is taking the fundamental risk framework that you might find in any other discipline and bringing the same principles into risk management,” he explains. It entails going through risk identification, risk polarization, and other activities where you’re considering various outcomes. “You’re looking at your worst case, your best case, and then you’re most likely case, and then running through your scenarios iteratively and then determining what are we most likely to achieve,” Andy remarks.
Revenue Governance
“The involvement and oversight of revenue generation activities by others in a cross-functional, a cross-departmental way in an organization,” is Andy’s definition for revenue governance. In the past, companies left the revenue engine in the sole hands of the sales department. Presently, revenue operations have been spread out to where even customer support can be responsible for it. The governance aspect relates to all entities in the organization having visibility into the activities of the sales department, and what they are doing. “Coupled with that is the opportunity to take action if something is not compatible with corporate strategy or if certain processes or activities that are occurring in generating revenue bring risk into the organization,” Andy adds.
The Future of Revenue Risk Management
Tom asks Andy to shed some light on what role revenue risk management will play in the coming decade. Risk management in the realm of sales is going to become more dominant. Even though most organizations haven’t put the formal risk management rigor to their sales department, they are thinking along those lines. There will also be a greater role for financial planning in the sales operations as more businesses become integrated.
Resources
Andy Rudin | LinkedIn | Twitter
Contrary Domino
This episode of the FCPA Compliance Report begins a special two-part series with two well-known compliance professionals. Matt Galvin, most recently the CCO at AB-InBev and Dan Kahn, former acting Deputy Assistant Attorney General of the Criminal Division, Chief of the Fraud Section, and Chief of the FCPA Unit. Dan is now in private practice at DavisPolk. In this Part 1 we take up the key issues around dealing with the DOJ including the factors which go into the decision to self-disclose, incentives and disincentives in compliance programs, internal investigations including who is involved and scoping an investigation, presenting information to the DOJ during the pendency of an investigation and negotiating the final settlement and post-resolution; including both ongoing reporting and continuing innovation in your compliance program.
Resources
Matt Galvin on LinkedIn
Dan Kahn at Davis Polk
Where does creativity fit into compliance? In more places than you think. Problem-solving, accountability, communication, and connection – they all take creativity. Join Tom Fox and Ronnie Feldman on Creativity and Compliance, part of the Compliance Podcast Network. In this episode, Tom and Ronnie begin a short series on provocative statements on compliance training and communications, followed by discussion. In this episode, why does a spoonful of sugar in the form of comedy and entertainment make compliance training and communications more engaging and effective.
Resources:
Ronnie Feldman (LinkedIn)
Learnings & Entertainments (LinkedIn)
Ronnie Feldman (Twitter)
Learnings & Entertainments (Website)
60-Second Communication & Awareness Shorts – A variety of short, customizable, quick-hitter “commercials” including songs & jingles, video shorts, newsletter graphics & Gifs, and more. Promote integrity, compliance, the Code, the helpline and the E&C team as helpful advisors and coaches.
Workplace Tonight Show! Micro-learning – a library of 1-10-minute trainings and communications wrapped in the style of a late-night variety show, that explains corporate risk topics and why employees should care.
Custom Live & Digital Programing – We’ll develop programming that fits your culture and balances the seriousness of the subject matter with a more engaging delivery.
Tales from the Hotline – check out some samples.
Welcome to the Great Women in Compliance Podcast, co-hosted by Lisa Fine and Mary Shirley.
In today’s episode, Lisa speaks with one of the “OG GWICs,” and one of the first interviewees, Ellen Hunt. Ellen joined Spark Compliance in 2021, and is always a supporter for women in compliance, and in compliance as a whole. Today, we follow up on her 2021 podcast, where Lisa and Ellen discussed how the E&C profession is addressing retaliation, and the importance of anti-retaliation as part of speaking up.
The main discussion is about organizational justice, and particularly aspects of procedural justice, as this is one where compliance professionals can have a huge impact. They discuss the concept of consistent discipline and fairness, and what that can mean. They also discuss when Will Smith slapped Chris Rock at the Oscars telecast from an organizational justice standpoint, and how similar issues play out in corporations.
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.
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Susan Divers, currently Director of Thought Leadership at LRN.
Susan graduated from George Washington University at night while working at the State Department during the day. Her legal career began Office of the Legal Advisor at the State Department and continued in London with two large law firms. I moved back to Washington, entered private practice, working first with Bob Strauss at Akin Gump and then moving over Sonnenshien’s DC office where she became a partner.
Resources
Susan Divers LinkedIn Profile
LRN
In this episode of Shout Outs and Rants, we submit the following for your consideration:
1. Jay Rosen rants the Academy of Motion Picture snubbing of the Director of Dune for Best Director when the picture won 6 other Oscars.
2. Matt Kelly shouts out to the Golden Raspberry Foundation, who award the ‘Razzie’s’ for withdrawing their previously created award of Worst Performance by Bruce Willis in a Bruce Willis movie after the actor retired due to Aphasia.
3. Jonathan Armstrong shouts out to Tina Turner for advancing the cause of GDPR and explaining once and for all time ‘what’s love got to do with it.’
4. Karen Woody shouts out to the magic of Harry Potter World in Orlando have what she described as ‘awesome’ roller coaster rides, well worth the 3-hour wait in line.
5.Tom Fox rants Academy of Motion Picture Arts and Sciences for their incompetent response to Will Smith slapping Chris Rock at the Oscars and reminds us that workplace violence is never acceptable.
The members of the Everything Compliance are:
The host and producer, ranter (and sometime panelist) of Everything Compliance is Tom Fox the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the Compliance Podcast Network.
