Tag: culture

Categories
Compliance Into the Weeds

Compliance into the Weeds: The COSO Governance Framework

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Are you seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the recently released COSO Corporate Governance Framework.

Tom and Matt take a deep dive into the new COSO Corporate Governance Framework draft. They discuss the importance of public comment on the draft, which is open until July 11, and explore the framework’s six key components. The framework aims to provide discipline in achieving good governance within organizations, covering areas such as strategy, culture, human resources, and resilience. Kelly highlights the significance of culture in compliance and the role of information quality in the future, providing practical tips on implementing and testing the framework. The episode highlights the importance of this framework for various stakeholders, encouraging practitioners to review and provide feedback on the draft.

Key highlights:

  • Overview of COSO’s Draft Corporate Governance Framework
  • The Six Objectives of the Framework
  • Importance of Culture in Compliance
  • Principles and Points of Focus
  • Resilience in Corporate Governance

Resources:

Matt Kelly in Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

A multi-award-winning podcast, Compliance into the Weeds, was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast.

Categories
Culture Crafters

Culture Crafters – Navigating Business Volatility Through Corporate Culture

It is always interesting when 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 cultivate the best culture possible. The reason is deceptively simple: the better the culture, the better the company. However, many business executives and even compliance professionals are unaware of how to create a culture that enables their employees, and thereby their organization, to implement such strategies. How can you unlock the power of a thriving workplace culture?

In this episode, host Tom Fox visits Sam Silverstein and Tara Stone to explore the impact of corporate culture on an organization’s ability to navigate volatile business environments, specifically using the recent tariff fluctuations as a backdrop. The conversation delves into how preemptively fostering a strong corporate culture can help companies withstand and even thrive during periods of significant change. Key emphasis is placed on the importance of trust, communication, accountability, and maintaining core values. Both Sam and Tara share insights on how leaders can prepare their organizations during stable times to better handle future challenges, drawing on their experiences and frameworks for building high-performance workplace cultures.

Key highlights:

  • Understanding Volatility in Corporate Culture
  • The Role of Trust in Navigating Volatility
  • Embracing Change and Overcoming Fear
  • Accountability and Leadership in Turbulent Times
  • Building Trust and Core Values

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tara Stone

Tara Stone on LinkedIn

Categories
Great Women in Compliance

Great Women in Compliance – Culture. Data. Ethics with Hui Chen

Hui Chen is a luminary in the world of Ethics and Compliance, and she is our guest on today’s episode of Great Women in Compliance. Today, Hui is one of the co-founders of CDE Advisors, which stands for “Culture. Data. Ethics.”

Most of us know Hui from her work at the Department of Justice (DOJ) and her contributions to the Evaluation of Corporate Compliance for the Fraud Section. However, my career path included being a prosecutor, in-house compliance work, and even being inspired to pursue a Master’s degree in Divinity after the 9/11 attacks.

Hui discusses the origins of the ECCP and her perspective on its current use. She also discusses the opportunity in the “FCPA pause” and how organizations can broaden their ethical considerations beyond foreign bribery to focus on relationships with all stakeholders. She discussed how the focus on regulatory guidance, particularly on bribery outside the United States, is just one of many areas to consider as a compliance professional. 

She also offers practical advice based on her experiences working with global compliance functions and the lessons she has learned.

Categories
Blog

Miri: Biohazards, Blind Spots, and Building a Culture of Preparedness

Show Summary

Today, we explore one of the eeriest and most profound cautionary tales in the Star Trek canon—Miri. When the crew responds to a distress signal from a planet that’s an exact duplicate of Earth, they find a society ravaged by a failed experiment in human longevity. Only children remain, while the adult “grups” have all died from a virulent disease.

This haunting story is not science fiction. It’s a case study of what happens when risk management is treated as an afterthought. We draw parallels between the biohazard breakdowns on the planet and the kinds of failures that modern compliance officers must guard against, whether in public health readiness, supply chain risk, or workforce welfare.

Key Highlights and Risk Management Case Illustrations

1. Disaster Preparedness—A Cure Without a Contingency Plan

Illustrated by: The civilization’s experiment to extend life, which instead wipes out all adults.

This central failure underscores the risks associated with scientific advancement that lacks proper risk assessment. The developers had no fallback, no regulatory oversight, and no crisis management framework in place. For compliance professionals, this serves as a reminder that innovation must be paired with effective scenario planning and disaster recovery protocols.

2. Environmental and Public Health Compliance—Invisible Risks Become Existential Threats

Illustrated by: The crew’s infection with the disease upon beaming down, with lesions appearing days later.

This serves as a metaphor for health and safety non-compliance. Enterprises must be vigilant about how workplace conditions, unseen hazards, and biological risks can impact staff and operations. Proactive monitoring and rapid-response mechanisms are essential components of any risk management strategy.

3. Data Governance and Early Warning Systems—Responding Too Late

Illustrated by: The automated distress signal continued even though no adult survivors remained.

The signal was still active, but no one was listening until it was far too late. In modern organizations, this is equivalent to ignoring audit logs, internal control alerts, or whistleblower reports that go unread. A culture of attentiveness to data and signals is crucial to catching issues before they cascade.

4. Supply Chain Risk—Critical Resource Shortages in the Field

Illustrated by: The crew’s struggle to develop a cure with limited time, no labs, and deteriorating conditions.

Kirk and McCoy were caught without adequate resources. This scenario mirrors the real-world risks companies face when they lack redundancy in their supply chains, fail to audit vendor health, or fail to plan for logistical disruptions. A robust compliance framework includes stress-testing the supply chain for resilience under duress.

5. Employee Welfare and Isolation—Psychological and Ethical Concerns in Hazard Zones 

Illustrated by: Spock’s decision not to return to the Enterprise due to the risk of contamination.

Spock’s sacrifice is a model of ethical risk containment. In any risk environment, whether it is a pandemic, data breach, or financial misconduct, companies must empower employees to make ethically sound decisions while providing mental health support for those isolated by crisis response roles.

Final ComplianceLog Reflections

Miri is a chilling illustration of what happens when ambition outpaces ethics and planning. The children left behind are the victims of a society that prioritizes progress over protection. For compliance professionals, this episode serves as a vivid reminder that a well-crafted compliance program is not just about preventing misconduct; rather, it is about preparing for the unknown.

Resources:

Excruciatingly Detailed Plot Summary by Eric W. Weisstein

MissionLogPodcast.com

Memory Alpha

Categories
FCPA Compliance Report

FCPA Compliance Report – The Role of Culture and Data in Fraud Risk Management: A Conversation with Vincent Walden

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. This is a very special episode. Today, Tom Fox cross-posts an episode from the BCG Podcast. In it, host Hanjo Siebert visits with konaAI CEO Vince Walden. They discuss the critical role of data and culture in achieving effective compliance, exploring the importance of interdepartmental collaboration, the evolving compliance landscape, and real-world examples of fraud detection. Walden emphasizes that while strategy is important, a strong organizational culture is essential for successful execution. He explains how data serves as a transparency agent and outlines the need for a collective approach to managing fraud risk. Listen in to gain insights into the challenges and best practices in modern compliance.

Key highlights:

  • The Importance of Transaction Monitoring
  • Challenges in Fraud Risk Management
  • Collaborative Approaches to Compliance
  • konaAI Role in Modern Compliance
  • Real-World Fraud Cases and Lessons Learned
  • The Impact of Business Culture on Fraud Prevention
  • Fostering a Culture of Transparency

Resources:

Vince Walden on LinkedIn

konaAI

Original Podcast Recording

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

For more information on the use of AI in Compliance programs, see my new book, Upping Your Game. You can purchase a copy of the book on Amazon.com.

Categories
Culture Crafters

Culture Crafters – Preventing and Fixing a Cultural Disconnect

It is always interesting when the regulators catch up to the business world. That is what has happened around corporate culture. The DOJ 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 that they can achieve. 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, look at how companies can elevate their culture to new heights. In this episode, Tom and Sam conclude their 3-part series on the increased importance of compliance after Trump’s Executive Order suspending FCPA enforcement. Part 3 of the crucial aspects of corporate culture and ethics are detailed in the L.R.N. Ethics and Compliance Program Effectiveness Report. We explore why lower-level employees often perceive management as insincere about ethical values, not due to grand crimes like bribery or corruption but because of smaller, more personal issues like unfair treatment and lack of transparency. Sam emphasizes that even minor inconsistencies can erode trust, leading to a lack of safety and increased employee suspicion. They detail practical steps for middle and senior management to enhance their communication and engagement skills, with an overarching message that culture must be diligently maintained to build a high-performance organization. 

Key insights:

  • Ensuring Fairness and Consistency in the Workplace
  • Strategies for Enhancing Corporate Culture
  • The Importance of Continuous Cultural Improvement
  • Developing Middle Management Communication Skills
  • Engaging Senior Leadership in Cultural Conversations

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Culture Crafters

Culture Crafters – Listening Up to Build a Speak Up Culture

It is always interesting when 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 that they can achieve. 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, look at ways companies can elevate their culture to new heights. In this episode, Tom and Sam continue their three-part series on the increased importance of compliance after Trump’s Executive Order suspending FCPA enforcement. In part 2, we discuss the importance of speaking up and listening up for corporate culture.

Key insights:

  • Proactive Listening Strategies for Leaders
  • The Importance of a Listening Strategy
  • The Disconnect in Perception of Company Culture
  • The Impact of Communication on Culture
  • Addressing the Disconnect with Data
  • The Importance of Perspective Seeking

 Resources:

 Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Culture Crafters

Culture Crafters – The Increased Importance of Corporate Culture During FCPA Suspension

It is always interesting when 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 that they can achieve. 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, look at how companies can elevate their culture to new heights. In this episode, Tom and Sam begin a three-part series on the increased importance of compliance after Trump’s Executive Order suspending FCPA enforcement.

Key insights:

  • Impact of Trump’s FCPA Suspension
  • Importance of Corporate Culture
  • Culture Audit and Employee Attraction
  • Workplace Culture and Innovation
  • Speak Up vs. Listen Up Culture

Resources:

Sam Silverstein

Sam Silverstein on LinkedIn

Sam Silverstein

The Culture Audit™

Tom Fox

Instagram

Facebook

YouTube

Twitter

Categories
FCPA Compliance Report

FCPA Compliance Report – Workplace Culture and Compliance with Alejandra Almonte and Ann Sultan

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast on compliance. In this episode, Tom welcomes Alejandra Almonte and Ann Sultan, both Members of Miller & Chevalier, and uses the EEOC’s release in 2024 of its Enforcement Guidance on Harassment in the Workplace as an introduction to considering compliance and the workplace under the new Trump Administration.

Ann and Alejandra dive deep into the EEOC’s 2024 enforcement guidance on harassment and explore the implications of recent Executive Orders from the Trump administration. The conversation extends to the necessity of risk assessments in the current climate, focusing on how companies can maintain safe and compliant workplaces amidst shifting policies. Ann and Alejandra share valuable perspectives on conflicts of interest, the intersection of workplace safety and emotional well-being, and strategies for fostering a positive organizational culture even in uncertain times. Do not miss this expert advice on navigating the complexities of workplace conduct and compliance in the evolving legal landscape.

Key highlights:

  • EEOC’s 2024 Enforcement Guidance on Harassment
  • Impact of Policy Changes on Workplace Conduct
  • Ensuring a Safe and Inclusive Workplace
  • Risk Assessments and Workplace Misconduct
  • Conflicts of Interest in the Workplace

Resources:

Miller & Chevalier

Ann Sultan

Ann Sultan on LinkedIn

Alejandra Almonte

Alejandra Almonte on LinkedIn

Culture@Work: Fall 2024

Tom Fox

Instagram

Facebook

YouTube

Twitter

LinkedIn

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 a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. 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, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.

In today’s episode, we dive into the critical role of senior management in fostering a strong corporate culture of compliance, as highlighted by the 2022 Monaco Memo and the 2020 FCPA Resource Guide, 2nd edition. Emphasizing that corporate culture is vital to a company’s success, we discuss how the DOJ assesses ethical cultures and the importance of senior management’s active participation in compliance efforts. The episode outlines five key factors to guide senior leadership in setting, modeling, and monitoring the right tone at the top. These include clear communication of values, personal commitment to those values, supportive systems, integration into decision-making, and empowering managers to make ethically sound decisions. We conclude with three takeaways: senior management must engage in compliance, the DOJ evaluates corporate culture during investigations, and CEOs should be seen as chief compliance ambassadors.

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, 5th edition, by clicking here.