Tag: culture

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Transforming a Corporate Culture in Crisis: Lessons from Boeing

There has not been a company that has had a run of worse publicity in 2024 than Boeing. Unfortunately, it has been self-inflicted. I recently participated in a webinar with Sam Silverstein on what Boeing can do to try and pull itself out of the miasma it now finds itself in, which has led to regulatory and criminal scrutiny, critical damage to its reputation, loss of market share, deterioration of its customer relationships, the resignation of its CEO, and destruction of trust within its massive workforce.

The webinar began with a dive into Boeing’s historical mergers, particularly with McDonnell Douglas in 1997, which marked a significant cultural shift within the company. Initially, Boeing was renowned for its high engineering standards, but post-merger, a more bottom-line-focused culture from McDonnell Douglas took precedence. This shift from quality to cost-efficiency laid the groundwork for the issues Boeing faces today.

This consequence of post-merger cultural misalignments led to deep-rooted issues. For Boeing, this resulted in a culture where the drive to reduce costs and increase profitability overshadowed the foundational emphasis on engineering excellence and safety. This cultural shift manifested in various high-profile crises, such as the 737 Max incidents, which were symptomatic of broader systemic problems—problems where the cultural ethos of safety and thoroughness was compromised. Further, when cultural values are misaligned with corporate actions, employee morale, and product quality suffer significantly.

The most important question for Boeing is how it begins a cultural comeback. It all begins with the top leadership, which plays a key role in any cultural transformation. The reason is straightforward: true change starts at the top—leaders must embody the values they wish to see throughout the organization. This involves more than just setting policies; it requires leaders to actively promote a culture of quality, safety, and integrity.

Fortunately, there is a blueprint for Boeing to begin a culture turnaround. It is the procedure that compliance professionals use to manage ethics and compliance risks. The process itself is simple, but execution is not always easy. The process of Assessment leads to Strategy Development, Strategy Implementation, Monitoring of Strategy Implementation, and Continuous Improvement.

With a company the size of Boeing, you need a comprehensive software tool that can assess the corporate culture in a wide variety of ways. Trust, ethics, health, safety, values, beliefs, clarity of mission, quality of decision-making, the value of people, the quality of engagement, accountability, innovation and change, and leadership are but some of the areas that need to be measured in your initial assessment.

In short, you need a tool designed to diagnose and understand your organization’s cultural health. This assessment is not just about identifying weaknesses but also reinforcing strengths. A culture assessment can offer actionable insights that guide strategic change by systematically analyzing various cultural facets—like accountability, ethics, employee engagement, and safety.

Using a software tool to diagnose and understand the current state of organizational culture, you will obtain data about the state of your culture and actionable insights that you can use to form the basis of your comeback strategy. A practical culture assessment can reveal areas of strength to build upon and weaknesses that require strategic interventions. For instance, if there is a deficiency in trust and safety in manufacturing, leadership can clarify that safety is the No. 1 priority. Management can celebrate those who come forward with safety issues in the manufacturing process instead of marginalizing them.

Next is implementing the strategy through training and communications throughout the company. Once again, such an approach is well-known to the compliance community. Further, it is simple but will require effort and commitment by senior management. In 2022, Boeing reported roughly 156,000 employees, representing 47 nationalities in 65 countries around the globe. Yet, think of Siemens’ comeback after its 2008 bribery and corruption scandal. With a similar number of employees around the globe, the company’s top leadership made it clear through in-person training and communications that a change would happen.

Not surprisingly, Siemens management found that employees were sick and tired of being known as a bribery and corruption company. Boeing employees are the same way. They take tremendous pride in working for their organization and will embrace any change to return to the company’s roots of quality and excellence.

Next is the ongoing monitoring of the implemented strategy, which forms an essential component going forward. You cannot simply implement your strategy; you must also monitor the results. Using software tools like the Culture Audit allows companies to gauge their progress and continuously make adjustments where necessary.

You then move to continuous improvement from monitoring. A data-driven approach will allow your organization to provide additional resources, communications, and training where needed. This continuous feedback loop is crucial to maintaining cultural health and aligning it with the company’s strategic objectives.

The lessons from Boeing are applicable globally across industries. Every organization aiming for long-term success must prioritize a culture aligned with its values and objectives. A healthy corporate culture supports a positive internal environment and enhances the company’s reputation and reliability in the eyes of its customers and stakeholders. For companies in cultural crisis, facing their cultural challenges head-on with transparent, actionable strategies offers a path to regain trust and ensure sustainable success. As corporate landscapes continue to evolve, the principles discussed will remain vital for any organization committed to meaningful, enduring change.

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Culture Crafters

Culture Crafters – Continual Culture Assessments

Seeing the regulators catch up to the business world is always interesting. That is what has happened to corporate culture. The Department of Justice is now assessing the corporate culture of any company under investigation. Rather than simply complying with this mandate, companies should strive to foster their best culture. The reason is deceptively simple: the better the culture, the better the company. However, many business executives and even compliance professionals do not know how to craft a culture that allows your employees and your organization to implement such strategies. How can you unlock the power of a thriving workplace culture?

In this podcast series, Sam Silverstein, the most trusted voice in America on accountability, and Tom Fox, the Voice of Compliance, discuss ways companies can elevate their culture to new heights. They discuss the power of continual assessments.

The importance of culture within organizations cannot be overstated; it serves as the backbone for organizational success and growth. Leadership’s power in shaping an organization’s culture requires leaders to live by the values they preach and ensure these values are mirrored in their actions. The existing culture should be continuously assessed through tools like culture audits. Achievements tied to the organization’s unique culture should also be celebrated.

Sam highlights that while all organizations have the potential to build a great culture, successful implementation depends mainly on leadership. He believes a strong, people-centric organizational culture can drive long-term success and growth. He urges the ongoing examination and enhancement of culture to foster a positive, high-performance work environment.

Key Highlights:

  • Cohesive Work Environment for Organizational Success
  • Cultural Audits for Organizational Success
  • The Need for Recognizing Workplace Success and Growth

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Sustaining Culture: Continually Improve Company Culture

What’s measured is treasured. If it is important, you want to know what is going on and improve on it. And it’s data; it’s factual. And so right away, we know what to do, and we can see the improvements we’re making because we can measure and improve them. Sam Silverstein.

I am in the middle of premiering a new podcast series, Culture Crafters, on the Compliance Podcast Network. In this series, together with Sam Silverstein, we are taking a deep dive into corporate culture: how to measure it, assess it, monitor it, and improve it. Through this exploration, we have uncovered the surprising truth behind sustained success in company culture. We have taken a deep dive into maintaining a high-performing culture that attracts and retains top talent. We have discussed the often overlooked strategy that propels companies to celebrate every win, big or small, and compound their growth year after year. Today, we continue our journey by considering why you should continuously audit and assess your culture to improve it.

Achieving and sustaining a great culture within organizations is foundational to long-term success. It involves creating an environment where individuals feel valued and motivated to contribute meaningfully towards shared goals. This process starts with leadership setting the tone by exemplifying behaviors prioritizing people’s well-being and professional growth. Leaders can inspire employees to engage fully and commit to the organization’s vision by fostering a culture of trust, respect, and open communication. Consistently reinforcing core values and recognizing contributions are key components in nurturing a positive culture that endures challenges and fosters innovation.

Regular culture audits are essential for organizations seeking to understand and improve their cultural dynamics. These assessments provide a baseline for measuring progress and identifying areas for growth. By gathering data on employee perceptions, engagement levels, and alignment with organizational values, companies can pinpoint strengths and weaknesses within their culture. This information allows leaders to tailor interventions, policies, and initiatives that align with the organization’s desired cultural outcomes.

Moreover, ongoing assessments enable organizations to adapt to changing circumstances and ensure that the culture remains aligned with evolving goals and external influences. Sam Silverstein’s discussion on culture audits highlights the value of using data-driven insights to inform decision-making and drive cultural improvements. He stresses the importance of combining qualitative feedback with quantitative metrics to understand the organization’s culture comprehensively.

By being transparent about assessment results, leaders can foster a culture of accountability and continuous improvement. Sam’s emphasis on the iterative nature of culture assessments underscores the need for organizations to view cultural dynamics as dynamic and evolving. The conversation underscores that continual assessment is not merely a one-time exercise but a strategic tool for maintaining a healthy and adaptive culture over time. You should develop a plan to assess and regularly improve your culture.

  • Culture Audit: Develop a culture audit to assess the current state of your company’s culture. This can help identify areas for improvement and set a baseline for future assessments.
  • Documentation: Document your culture assessment findings and improvement plans. Utilize tools to create and maintain detailed records of your culture assessment and improvement initiatives.
  • Regular Assessment: Implement a schedule for culture assessments, such as quarterly or bi-annually. Use tools to gather feedback and measure progress over time.
  • Celebrate: Incorporate a culture of celebration within your organization. This can include employee recognition programs, town hall meetings, or even small gestures like personalized notes or tokens of appreciation.
  • Continuous Improvement: Based on the results of your culture assessments, develop a plan for continuous improvement. Use project management tools like Asana, Trello, or Monday.com to track and execute improvement initiatives, ensuring that progress is ongoing and continuous.

The bottom line is that authentic leadership plays a pivotal role in shaping a thriving culture. Compliance professionals and business leaders go beyond superficial gestures and genuinely prioritize the well-being of their teams. Leaders can create a culture where individuals feel respected and valued by demonstrating care and investment in employees’ development. Key traits include actively listening to employee feedback, providing growth opportunities, and demonstrating ethical decision-making. Ultimately, the conversation reveals that sustained success in company culture hinges on leaders’ commitment to prioritizing people and consistently reinforcing a positive work environment.

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Culture Crafters

Culture Crafters – A Deep Dive into Culture Assessments

It is always interesting to see the regulators catch up to the business world. That is what has happened to corporate culture. The Department of Justice is now assessing the corporate culture of any company under investigation. Yet more than simply complying with this mandate, companies should strive to foster the best culture they can. The reason is deceptively simple: the better the culture, the better the company.

But many business executives and even compliance professionals do not know how to craft a culture that allows your employees and, thereby, your organization to implement such strategies. How can you unlock the power of a thriving workplace culture?

In this podcast series, Sam Silverstein, the most trusted voice in America on accountability  and Tom Fox, the Voice of Compliance, look at the ways companies can elevate their culture to new heights.

In this episode, they take a deep dive into culture assessments, highlighting the significance of this process in maintaining effective leadership, employee engagement, diversity, equity, and inclusion.

Comprehensive assessment is a cornerstone for the success of organizations, underpinning their ability to identify weaknesses, implement improvements, and foster a strong ethical culture. Tom and Sam underscore the necessity of a comprehensive assessment for leaders to understand and manage all crucial aspects of their organizations, a neglect of which could be seen as negligence.

They stress the importance of assessment in addressing key areas like stress, diversity, and ethics to attract top talent and boost productivity, profitability, and overall performance. Both advocates believe that without comprehensive assessment, organizations fail their stakeholders and harm their own success and reputation.

Key Highlights

  • Ethical Strength Assessment in Organizational Culture
  • Enhancing Organizational Performance through Comprehensive Assessment
  • Trust-Based Culture Audit for Effective Leadership
  • Foundational Elements for Collaborative Team Success
  • Inclusive Workplace Dynamics for Organizational Success

Resources 

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Blog

Role of Leadership in Culture and Course Correcting

Many people focus on qualities like decisiveness, communication skills, and strategic thinking when it comes to leadership. While these traits are undoubtedly important, another aspect of leadership often gets overlooked: the role of culture. An organization’s culture can significantly impact its success, and leaders who understand and prioritize this aspect can create a more positive and productive work environment. In this blog post, we will explore the importance of culture in leadership and provide practical tips for harnessing its power.

Why is it important to hire leaders who understand and prioritize the existing culture or improve it if needed? Leaders who understand and prioritize an organization’s existing culture are better equipped to make informed decisions that align with its values and goals. By hiring culturally sensitive leaders, you can ensure they will respect and uphold your organization’s unique traditions and norms. Additionally, leaders in tune with the culture are more likely to inspire employee trust and loyalty, leading to higher engagement and job satisfaction.

To hire leaders who understand and prioritize the existing culture, every organization should consider incorporating questions about cultural fit into their interview process for anyone being reviewed and interviewed. Your organization should seek candidates who demonstrate an awareness of your organization’s values and a willingness to embrace its culture. Additionally, new leaders should be provided with training and resources to help them acclimate to the culture and understand how their actions can impact it.

What happens if something goes wrong, and how should your compliance function address behavior that undermines the organizational culture? The most direct, perhaps significant, method is to address behavior that undermines the organizational culture promptly and directly. The reason is that when left unchecked, negative behavior can erode trust, create conflict, and harm employee morale. Compliance professionals should proactively address behavior that goes against the organization’s values by setting clear expectations, providing feedback, and offering support to help employees correct their course.

When addressing behavior that undermines the organizational culture, you should focus on open communication, active listening, and constructive feedback. It is important to address issues as they arise and involve HR, compliance, or other resources to ensure a fair and respectful resolution. With compliance as the herald of Organizational Justice and Fairness, you can see the compliance angle in all these matters. By addressing negative behavior head-on, your organization can communicate that its culture is non-negotiable and everyone is expected to uphold its values.

A culture audit is one of the key ways to determine if your organization needs to correct its course. Implementing cultural audits in an organization can help leaders gain valuable insights into the culture’s current state and identify areas for improvement. By conducting regular assessments of the culture, leaders can track progress, measure the impact of initiatives, and make data-driven decisions about strengthening and promoting the organization’s values. Cultural audits can also help leaders identify potential risks, such as issues related to diversity and inclusion, and take proactive steps to address them.

The Department of Justice (DOJ) has also recognized culture management as a critical element for compliance. Beginning with the speech by Deputy Attorney General Lisa Monaco in October 2021, she discussed the need for companies to assess, manage, monitor, and improve their corporate culture. This was memorialized in the 2023 Evaluation of Corporate Compliance Programs (2023 ECCP) update. In the 2023 ECCP, the DOJ asks the following questions: how often and how does a company measure a culture of compliance? What are your hiring and incentive structures around compliance? What steps have you taken in response to your measurements of compliance?

All these questions posed by the DOJ lead to the requirement that every company needs to assess its culture because the DOJ will take any enforcement action or review. However, it can be done using the same current compliance processes, as culture is just like any other risk. As a risk, it can be assessed. This is why a culture audit is critical for you to perform to ensure your corporate culture is where it should be. When you have assessed your culture, you can start to put together a management strategy to improve and correct your corporate culture. With your culture strategy in place, you can train your employees and monitor their performance, determining the results. From there, you can improve your culture strategy as needed. But it all starts with a culture audit.

To implement cultural audits in your organization, consider working with an external consultant or HR professional specializing in organizational culture. Develop a comprehensive audit plan that includes surveys, focus groups, interviews, and observations to gather data from various sources. Use the insights gained from the audit to develop a strategic action plan to strengthen the culture, address concerns, and foster a positive work environment for all employees.

In conclusion, the importance of culture in leadership cannot be overstated. Leaders who understand and prioritize an organization’s existing culture can create a more positive and productive work environment, inspire trust and loyalty among employees, and drive success. By hiring culturally sensitive leaders, addressing behavior that undermines the organizational culture, and implementing cultural audits, organizations can strengthen their values, build a strong foundation for growth, and create a workplace where everyone can thrive.

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Culture Crafters

Culture Crafters: Assessing Your Culture Through The Culture Audit™

It is always interesting to see the regulators catch up to the business world. That is what has happened around corporate culture. The Department of Justice is now assessing corporate culture for any company under investigation. Yet more than simply complying with this mandate, companies should strive to foster the best culture they can. The reason is deceptively simple: the better the culture, the better the company. But many business executives and even compliance professionals do not know how to craft a culture that allows your employees and, thereby, your organization to implement such strategies. How can you unlock the power of a thriving workplace culture?

In this podcast series, Sam Silverstein, the most trusted voice in America on accountability  and Tom Fox, the Voice of Compliance, look at the ways companies can elevate their culture to new heights.  In this inaugural episode, they discuss how to assess your culture through the Culture Audit™.

The concept of a culture audit is a transformative tool that assesses an organization’s critical areas such as ethics, engagement, accountability, and diversity, offering valuable insights for improvement and fostering a high-performance work culture.

Tom posits that the culture audit not only measures these critical areas but also guides action plans for improvement, emphasizing continual assessment and prioritization of key cultural drivers for genuine change.

Similarly, Sam Silverstein underscores the necessity of conducting a culture audit to discern an organization’s cultural strengths and weaknesses. He asserts that culture directly affects an organization’s bottom line, citing instances where cultural improvements have significantly boosted performance, profits, and employee retention. For Silverstein, a comprehensive culture audit from the boardroom to the shop floor is fundamental for developing a positive and high-performing work environment.

Key Highlights:

  • Enhancing Organizational Culture for High Performance
  • Cultivating Accountability and Excellence for Success
  • Enhancing Workplace Culture through Detailed Assessment
  • Transparent and Traceable Culture Audit Findings
  • High-Performance Culture: Driving Financial Success

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Blog

Auditing Culture

Why should you audit your culture? A compliance professional can utilize a comprehensive approach to evaluate various aspects of a company’s culture, including ethics, engagement, accountability, and diversity. Tom Fox and Sam Silverstein took up this topic in the inaugural episode of the Culture Crafters podcast. Silverstein emphasized the pivotal role of a high-performance culture in attracting and retaining top-tier talent, ultimately leading to improved company performance and profitability. According to Silverstein, the shortest and quickest path to organizational transformation is through culture, as it forms the core of all change.

Beginning with the speech by Deputy Attorney General Lisa Monaco in October 2021, they recognized the need for companies to assess, manage, monitor, and improve their corporate culture. This was memorialized in the 2023 Evaluation of Corporate Compliance Programs (ECCP) update, announced in January 2023. In the ECCP, the DOJ asks the following questions: how often and how does a company measure a culture of compliance? What are your hiring and incentive structures around compliance? What steps have you taken in response to your measurements of compliance?

All these questions posed by the DOJ lead to the requirement that every company assess its culture because the DOJ will take any enforcement action or review. However, it can be done using the same current compliance processes, as culture is just like any other risk. As a risk, it can be assessed. This is why a culture audit is a necessary first step in determining where your culture is, what needs improvement, and how to do so.

As important as it is to meet these DOJ expectations, the real power is to create a high-performing culture to allow your organization to grow to its potential. Focusing on a high-performance culture can lead to an 80% increase in performance, profits, and employee retention, fostering a productive work environment and driving overall success. The bottom line is that a high-performance culture is essential for attracting and retaining top-tier talent and can significantly improve a company’s performance and profitability.

Every compliance professional understands that you must first assess your risks in risk management. When you have assessed a risk, you can start to put together a risk management strategy. The same is true for corporate culture. You must first assess where your culture is and then move forward to improvement through culture and a culture management strategy. With your culture strategy in place, you can train your employees and monitor their performance, determining the results. From there, you can improve your culture strategy as needed. But it all starts with a culture audit.

The steps are familiar to every compliance professional.

  1. Assess Every Level. To gain a comprehensive understanding of the company’s culture, you must assess everyone in the organization, not just senior leadership.
  1. Continuous Improvement. After conducting the culture audit, organizations must receive a detailed Culture Audit Report, which includes responses and action plans. This report serves as a roadmap for companies to focus on key drivers, enhance alignment, and continuously improve their workplace culture.
  1. Sustain High Performance. Focus on building a high-performance culture can yield remarkable results, including an 80% increase in performance, profits, and employee retention. Creating a culture that inspires individuals to excel and be accountable is essential for long-term success.

To facilitate this, Silverstein created Culture Audit™. The Culture Audit is a software solution that assesses critical areas of a company’s culture, such as ethics, engagement, accountability, and diversity, providing actionable insights for improvement. Available in over 20 languages, it aids in transforming a company’s culture for sustainable high performance. A high-performance culture is essential for attracting and retaining top-tier talent and can significantly improve a company’s performance and profitability. The Culture Audit Report, a detailed document with responses and action plans, enables organizations to enhance their workplace culture effectively. The audit results are auditable, ensuring accurate conclusions and data traceability, adding credibility to the process. Focusing on a high-performance culture can lead to an 80% increase in performance, profits, and employee retention, fostering a productive work environment and driving overall success.

Silverstein encapsulates the essence of culture transformation: “The shortest, quickest path to seeing transformation in an organization is always through the culture because that’s at the core of all transformation.” Every business is incumbent upon preparing a comprehensive document that takes a deep dive into its culture assessment results and guides it on the path to improvement. This report is a foundation for implementing educational initiatives, training programs, and organizational transformation.

In conclusion, the culture audit is not a one-time fix but a continuous process that requires regular assessment and improvement. By prioritizing a high-performance culture, companies can create a productive work environment, attract top talent, and drive overall success.

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Blog

Argentieri at ABA White Collar Conference: Compliance Programs, Part 2

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco. The second was by Acting Assistant Attorney General Nicole Argentieri. They both had important remarks for the compliance professional. I have taken a deep dive into both speeches and what indicates compliance programs, compliance professionals, DOJ expectations, and Foreign Corrupt Practices Act (FCPA) enforcement going forward. We have previously considered the Monaco speech and began exploring the speech by Nicole Argentieri. Today, we conclude with remarks by Argentieri regarding how the DOJ will put these policies into practice and what they mean for compliance professionals and programs going forward.

Robust Compliance

The DOJ has either concluded or is in the middle of an FCPA industry sweep through oil and energy trading companies. In addition to Gunvor, there have been enforcement actions involving Vitol Trading, Glencore, and Freepoint. Argentieri noted that as a part of their resolutions with the DOJ, “each of these trading companies was required to make critical enhancements to their compliance programs to prevent future violations of the FCPA. Companies that take forward-leaning steps on compliance will be better positioned to certify that they have met their compliance obligations at the end of the term of their agreements, as is now required in corporate resolutions with the Criminal Division. These prosecutions also help set the tone for the energy trading industry as a whole — they show that a robust compliance function is critical.”

Corporate Culture

It all begins with corporate culture. The DOJ will assess the corporate culture and a company’s prior misconduct in determining the appropriate form of resolution and the financial penalty. This is where culture becomes critical, particularly for the recidivist, because, as Argentieri noted, “we will not hesitate to require substantial penalties — including, where appropriate, guilty pleas — for companies that show themselves to be repeat offenders.”

Coupling that statement with the superior resolution obtained by ABB and Albemarle shows that the DOJ is serious about corporate culture. The bottom line is that a company can move to a culture of compliance if senior management is committed to the effort. One need only consider the superior result obtained by the first three-time recidivist ABB. Culture is critical, and you must demonstrate that you have assessed and worked to improve your corporate culture.

Clawbacks and Holdbacks

One of the key initiatives brought forward under DAG Monaco’s tenure has been around incentives and consequences. However, under DAG Monaco’s tenure, incentives and consequence management were further refined in the 2023 Evaluation of Corporate Compliance Programs (2023 ECCP). It was also enshrined in the DOJ Compensation Incentives and Clawbacks Pilot Program (Pilot Program), which has two components: (1) incentivization of compliance and (2) disincentives through clawbacks and holdbacks.

Argentieri pointed to the SAP resolution as a key example of how clawbacks and holdbacks can benefit a company. She noted, “Even before its criminal resolution, SAP had adjusted its compensation incentives to align with compliance objectives and reduce corruption risk.” She said, “SAP also took advantage of the second part of the Pilot Program, which allows companies to reduce their fines when they withhold compensation from culpable employees.” The DOJ “reduced SAP’s criminal penalty by over $100,000 for compensation that the company withheld from certain employees.”

However, the pilot program requires a real effort from the company regarding clawbacks and holdbacks. SAP “went to great lengths to defend this corporate decision, including through litigation.’ Argentieri believes that “These actions sent a clear message to other SAP employees—and employees of companies everywhere—that misconduct will have individual financial consequences. This is another example of the company’s remediation that supported our decision to award a 40% fine reduction.”

Before SAP, Albemarle was “the first company to receive a fine reduction under the Pilot Program in an FCPA resolution last year.” While Gunvor did not engage in clawbacks or holdbacks, Argentieri applauded their efforts in incentivizing compensation, relating that “Gunvor had already updated and evaluated its compensation policy better to incentivize compliance with the law and corporate policies.”

Argentieri concluded this section by stating, “All of these policies should send a simple, but strong, message: being a good corporate citizen is not just the right thing to do. It is good business. Those who step up will be able to unlock the benefits afforded by our policies. And those who do not will face stiff punishments. And for companies making the tough decision of whether to disclose, take note — we now have more ways than ever to discover misconduct.”

The Bottom Line

DAG Monaco’s speeches and Nicole Argentieri’s provided significant information for the compliance professional. Both are the DOJ expectations for a best practices compliance program and what a company needs to do if they find themselves under an FCPA investigation. DAG Monaco made four key points: (1) the DOJ will invest the most significant resources in the most serious cases, hold individuals accountable, and pursue tough penalties for repeat offenders absent a significant culture shift and remediation. (2) The Voluntary Self-Disclosure Program is a key component of enforcement and incentives. (3) The DOJ whistleblower bounty program should lead to new referrals to the DOJ. (4) Compliance professionals should be ready to address new, disruptive technologies, such as the rise of AI, through their corporate enforcement programs.

Argentieri emphasized details in compliance programs. It all starts with corporate culture, but companies must strive towards robust compliance programs, including effective internal controls, incentives for employees to work ethically and in compliance, and significant consequences for failure to do so: vigorous internal reporting, triage, and investigative protocols. Compliance professionals and compliance programs have never been more important for companies.

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Compliance Tip of the Day

Compliance Tip of the Day: The Importance of Culture

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 this episode, we explain the importance of corporate culture in the highest-risk areas for your organization. If you are an airline manufacturer, it’s the safety of your airplanes.

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

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Daily Compliance News

Daily Compliance News: February 27, 2024 – The He Lied Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance related stories to start your day. Sit back, enjoy a cup of morning coffee and listen to the Daily Compliance News. All from the Compliance Podcast Network. Each day, we consider four stories from the business world: compliance, ethics, risk management, leadership, or general interest for the compliance professional.

In today’s edition of Daily Compliance News:

For more information on Ethico and a free White Paper on top compliance issues in 2024, click here.