Tag: culture

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 4 – Assessing and Aligning your Corporate Values

One of the concepts enshrined in the Monaco Memo is that the Department of Justice (DOJ) will assess corporate culture for any company that may find itself under investigation for Foreign Corrupt Practices Act (FCPA) violations. This enshrinement is not exactly new as Deputy Attorney General (DAG) Lisa Monaco announced this new DOJ focus in October 2021 in her speech. The parameters of how the DOJ will assess culture are still being worked out but Chief Compliance Officers (CCOs) and compliance professionals need to consider this issue in the context of their own compliance programs and corporate culture in case the DOJ ever comes knocking. Over the next several blog posts, I will be exploring how a corporate compliance function can assess, monitor, and improve your corporate culture.

We begin with assessing your corporate values and then aligning them within your organization. In a recent Harvard Business Review (HBR) article, entitled What Does Your Company Really Stand For?, authors Paul Ingram and Yoonjin Choi explored these and other issues. The authors believe that corporate values are more critical than ever. I have adapted their work for the compliance professional.

The authors developed a five-step approach for values alignment.

1.     Identify the values within your employee base and create a values structure.

2.     Identify key priorities from strategy to determine what is the most important thing the organization can do to achieve its strategy.

3.     Wed values that serve both the organization and its employees.

4.     Begin the assessment process.

5.     Generate a final list of organizational values.

From the compliance perspective, the protocol. Recognizing that values are but one part of an overall corporate culture, gives you a mechanism to think through how to begin an overall assessment of your organization. Values do make up a portion of an overall culture. Through the engagement advocated herein, you can not only get a good reading on such key values as trust and respect but, more importantly, learn how to incorporate them as overall assets into your corporate culture.

Three key takeaways:

1. The Monaco Memo enshrined the concept that the DOJ will assess culture.

2. What does your company stand for?

3. When properly aligned, values can be a powerful part of corporate culture.

Check the free webinar on the new tool, The Culture Audit with Tom Fox and Sam Silverstein on Tuesday, November 20, 12 CT. For more information and registration, click here.

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GalloCast

Gallocast-Episode 12: Halloween and Day of the Dead

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the Gallocast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is an excellent insight on compliance brought to you by the co-CEOs of ComplianceLine. Fun, witty, and insightful with a dash of the two brothers throughout. It is like listening to the Brothers Gallo talk about compliance at the Sunday dinner table. Hosted by Tom Fox, the Voice of Compliance.

Halloween and Day of the Dead are just past us as the Brothers Gallo return for another Gallocast. Nick Gallo, in discussing SBF and FTX, emphasizes the importance of legal guidance and accountability in navigating complex ethical issues. He believes in the power of effective communication and strategic leadership in advocating for corporate ethics and compliance. On the other hand, Gio Gallo, with his focus on storytelling and advocacy, stresses the significance of securing budget allocation towards compliance and ethics from the executive suite. He believes a cultural shift within the organization involving a diverse group of individuals is crucial in addressing compliance and ethics challenges. Join Tom Fox, Nick Gallo, and Gio Gallo as they delve deeper into these topics in this episode of the GalloCast podcast.

Key Highlights:

  • SBF and Advice of Counsel defense. Where does the leadership buck stop?
  • RTW or WFH. How should an employer(s) approach this topic?
  • DS Disco- Why would 25% of the workforce write a letter to BOD asking them to fix corporate culture?
  • At what point should a start-up build out its internal controls? How about a compliance program?
  • How transparent should your whistleblowing process be with a reporter?
  • UM, the football program, is being investigated for electronic sign stealing.
  • What happens if a whistleblower allegation is made in bad faith?

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter

LinkedIn

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31 Days to More Effective Compliance Programs

One Month to a More Effective Compliance Program Through Culture: Day 3 – Compliance and Corporate Principles in Today’s World

For corporations, navigating the political landscape has become an increasingly difficult task. While being admonished to ‘stay in their lane’ by some, businesses are just like their stakeholders, impacted by the ever-changing political miasma. When this new reality is coupled with the new levels of transparency in companies, which are only amplified by social media, a company can be embroiled in public controversies with one or more stakeholder groups. As these situations occur, CCOs and compliance professionals will be called upon to help companies navigate this fraught process.

How can compliance help a company navigate through all of this? To make and implement the best strategic choices in this environment, leaders will have to

  1. develop principles to guide strategic choices,
  2. address ethical issues early on,
  3. consistently communicate and implement their choices,
  4. engage beyond the industry to shape the context and
  5. learn from mistakes to make better choices in the future.

This is a process that the corporate compliance function can facilitate. If you work through these steps, you should be able to prepare your organization for the next major shock.

 Three key takeaways:

1. Why a company can no longer simply ‘stay in its lane’.

2. Compliance should lead the way to develop robust principles to guide cultural choices.

3. Even in culture, continuous improvement is a mandate.

Categories
GalloCast

Gallocast – Episode 12: Halloween and Day of the Dead

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the Gallocast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is an excellent insight on compliance brought to you by the co-CEOs of ComplianceLine. Fun, witty, and insightful with a dash of the two brothers throughout. It is like listening to the Brothers Gallo talk about compliance at the Sunday dinner table. Hosted by Tom Fox, the Voice of Compliance.

Halloween and Day of the Dead are just past us as the Brothers Gallo return for another Gallocast. Nick Gallo, in discussing SBF and FTX, emphasizes the importance of legal guidance and accountability in navigating complex ethical issues. He believes in the power of effective communication and strategic leadership in advocating for corporate ethics and compliance. On the other hand, Gio Gallo, with his focus on storytelling and advocacy, stresses the significance of securing budget allocation towards compliance and ethics from the executive suite. He believes a cultural shift within the organization involving a diverse group of individuals is crucial in addressing compliance and ethics challenges. Join Tom Fox, Nick Gallo, and Gio Gallo as they delve deeper into these topics in this episode of the GalloCast podcast.

Key Highlights:

  • SBF and Advice of Counsel defense. Where does the leadership buck stop?
  • RTW or WFH. How should an employer(s) approach this topic?
  • DS Disco- Why would 25% of the workforce write a letter to BOD asking them to fix corporate culture?
  • At what point should a start-up build out its internal controls? How about a compliance program?
  • How transparent should your whistleblowing process be with a reporter?
  • UM, the football program, is being investigated for electronic sign stealing.
  • What happens if a whistleblower allegation is made in bad faith?

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
GalloCast

GalloCast: Episode 11 – CEOs Behaving Badly

Welcome to the GalloCast. You have heard of the Manningcast in football. Now we have the Gallocast in compliance. The two top brothers in compliance, Nick and Gio Gallo, come together for a free-form exploration of compliance topics. It is a great insight on compliance brought to you by the co-CEOs of ComplianceLine. Fun, witty, and insightful with a dash of the two brothers throughout. It’s like listening to the Brothers Gallo talk compliance at the Sunday dinner table. Hosted by Tom Fox, the Voice of Compliance.

Football season returns to this brings another season of the GalloCast. Nick and Gio are both known for their outspoken nature and deep understanding of workplace dynamics, CEO-worker relationships, and ethical decision-making. Nick believes in the importance of ethical sourcing, labor and social responsibility, and community engagement in creating a beneficial workplace environment. He emphasizes the role of the compliance and ethics team in ensuring ethical practices and the balance between self-interest and the well-being of employees and stakeholders. On the other hand, Gio stresses the importance of authenticity and cultural change in improving workplace dynamics. He believes that a mere change in name or logo is not enough, there needs to be an authentic push by leadership to build a culture of integrity. Join Tom Fox and the Gallo brothers, Nick and Gio, on this episode of the GalloCast.

Key Highlights

·       Do workers need to see pain?

·       CEOs behaving badly. 2 top CEOs resign for having affairs with subordinates or outright harassment. Rubiales resigns.

·       Huge oil field discovered of Namibia. How should a company prepare?

·       SEC probes Musk corporate perks.

·       CBRE busted over pre-taliation. Why having the right contract language is important.

·       Will a name change for SNC-Lavalin help it overcome its corrupt past?

·       SCCE. What are you expecting?

 

Resources

Nick Gallo on LinkedIn

Gio Gallo on LinkedIn

Ethico

Tom Fox 

Connect with me on the following sites:

Instagram

Facebook

YouTube

Twitter

LinkedIn

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Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 5 – Alexander Cotoia on the Continuous Improvement of Culture

Welcome to a special series on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. I will visit with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael Parker, and Alexander Cotoia in this series. Over this series, we will consider what culture is, how to assess culture, putting together a strategy to manage culture based upon this assessment, monitoring that strategy in the future, and using information from your monitoring to improve your culture continuously. In this concluding Part 5, we visit with Alexander Cotoia to discuss a strategy to enhance your compliance program in the future constantly.

Alexander Cotoia, a regulatory compliance manager and consultant at the Volkov Law Group, has a rich background in commercial litigation and has spent a significant part of his career in an in-house role at Virgin Galactic. Alexander strongly emphasizes the importance of compliance culture in organizations, believing that a culture promoting compliant behavior reduces the likelihood of ethical lapses or legal violations. He argues that creating a culture of compliance is not only ethically sound but also makes good business sense in today’s era, where consumers are well-informed and employees prioritize alignment with organizational values. Alexander suggests that organizations should reinforce their values and highlight the economic benefits of compliance to gain employee buy-in and engagement, emphasizing the need for continuous improvement, conducting root cause analysis, and involving various stakeholders to address cultural issues effectively. Join Tom Fox and Alexander Cotoia as they dive deep into how to continuously improve your compliance program in this episode of Unlocking Success: The Crucial Role of Culture in Compliance Best Practices podcast episode.

Key Highlights: 

  • Cultivating CEO Involvement for Compliance Success
  • Improving Corporate Culture through Effective Monitoring
  • Cultivating Compliance Culture through Stakeholder Collaboration

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com.

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Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 3 – Jessica Czeczuga on Creating a Strategy to Manage Culture

Welcome to a special series on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. I will visit with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael Parker, and Alexander Cotoia. Over this series, we will consider what culture is, how to assess culture, putting together a strategy to manage culture based upon this assessment, monitoring that strategy in the future, and using information from your monitoring to improve your culture continuously. In Part 3, we visit with Jessica Czeczuga on how to develop a strategy to manage your culture risk.

Jessica Czeczuga is a seasoned professional with over two decades of experience in training and development, specializing in areas such as finance, quality, compliance and ethics, leadership, and communication training. Jessica brings a unique perspective to the compliance space, emphasizing the pivotal role of managers in shaping and reinforcing company culture. She believes that managers, the most influential group within an organization, should be adequately trained to align with the desired culture and equipped with the necessary tools to communicate and reinforce cultural values effectively. Jessica also advocates for collaboration between compliance professionals and HR to improve culture, leveraging their counseling skills and creating clear processes for reporting and addressing culture-related issues. Join Tom Fox and Jessica Czeczuga as we dive deeply into this topic in this Unlocking Success: The Crucial Role of Culture podcast episode.

Key Highlights: 

  • The Impact of Managers on Company Culture
  • Collaborative Partnership: HR and Compliance Driving Reporting
  • The Role of Managers in Shaping Culture

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com.

 Join us tomorrow, where we consider how to monitor culture going forward.

Categories
Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 2 – Viktor Culjak on Assessing Culture

Welcome to a special series on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. I will visit with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael Parker, and Alexander Cotoia in this series. Over this series, we will consider what culture is, how to assess culture, putting together a strategy to manage culture based upon this assessment, monitoring that strategy in the future, and using information from your monitoring to improve your culture continuously. In Part 2, we visit with Viktor Culjak to discuss assessing culture.

Viktor Culjak is a chartered accountant with a strong finance, audit, and risk consulting background. Currently serves as the Director of Customer Success and Services at Diligent. With a decade of experience in the Big Four and a focus on governance, risk, and compliance (GRC) objectives, Viktor firmly believes in assessing and managing organizational culture as a risk factor. He views culture as a dynamic risk that can have significant consequences if not properly managed and advocates for standardized and benchmarked culture assessments to provide valuable insights for risk management. Viktor emphasizes the need for practical guidance on implementation, highlighting the significance of tone at the top and other artifacts such as policies, procedures, and feedback mechanisms in culture assessments. Join Tom Fox and Viktor Culjak as we delve deeper into assessing culture on this episode of the Unlocking Success: The Crucial Role of Culture podcast.

Key Highlights: 

·      Assessing and Auditing Organizational Culture

·      Creating a Culture of Effective Communication

·      Evaluating Culture Alignment for Continuous Improvement

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture.

For more information and to book a demo, visit Diligent.com

 Join us tomorrow, where we consider how to create a culture management strategy.

Categories
Innovation in Compliance

Unlocking Success: The Crucial Role of Culture in Compliance: Part 1 – Yvette Hollingsworth – Clark on What is Culture?

Welcome to a special series on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. I will visit with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael Parker, and Alexander Cotoia in this series. Over this series, we will consider what culture is, how to assess culture, putting together a strategy to manage culture based upon this assessment, monitoring that strategy in the future, and using information from your monitoring to improve your culture continuously. In Part 1, we ask what culture is with our special guest, Yvette Hollingsworth-Clark.

Yvette Hollingsworth-Clark, a seasoned professional in the financial services industry, currently holds the position of Chief Compliance Officer for State Street Corporation. With a robust background in risk management, Yvette has cultivated a deep understanding of the significance and measurement of corporate culture in the financial sector. She asserts that corporate culture should not be solely managed by the compliance function but rather owned by the C-suite and executed in various forms. Yvette emphasizes the need for specific metrics to monitor and promote desired cultural values, such as integrity. She believes culture can be measured through metrics such as the number of risk decisions overruled, challenged, or implemented correctly. She also highlights the importance of considering stakeholders such as customers, clients, and third parties when assessing corporate culture. Join Tom Fox and Yvette Hollingsworth-Clark on this episode to delve deeper into this topic.

Key Highlights:

  • Measuring and Managing Corporate Culture in Finance
  • Shaping Corporate Culture: Board’s Key Role
  • The Nuances of Assessing Organizational Culture

Ready for Purpose-Driven Compliance? Diligent equips leaders with the tools to build, monitor, and maintain an open, transparent ethics and compliance culture. For more information and to book a demo, visit Diligent.com

Join us tomorrow, where we consider how to assess your culture.

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Report from IMPACT 2023

Report from IMPACT 2023: Nick Gallo on Generational Change in the Workplace and Importance of Culture

ECI’s IMPACT 2023 was one of the leading compliance events in 2023. At this conference, Tom Fox, the Voice of Compliance, was able to visit with several of the speakers, exhibitors, participants and one group of ethically minded Girl Scout Troop. In this limited podcast series, Report from IMPACT 2023, Tom explores many of the most cutting-edge topics in ethics and compliance through short podcast episodes. Check out the full series of interviews. You will be enlightened, informed and come away with a fuller and more thorough understanding of the most cutting-edge topics in ethics and compliance. In this episode, Tom visits with Nick Gallo, co-CEO at Ethico and Keynote speaker at Impact 2023. He and Tom talk about the themes from Nick’s Keynote.

Nick Gallo brings a wealth of experience from his background in private equity to the discussion of the changing landscape of work, ethics and culture. Gallo’s unique insights are shaped by his belief that traditional hierarchical structures in workplaces have been replaced with more flat and remote structures, presenting a significant opportunity for industry transformation. Drawing from his firsthand experience during his PE acquisitions and mergers career, he emphasizes the critical role of authentic culture in enhancing employee engagement and performance. Gallo also highlights the need for aligning personal values with the purpose of an organization, a concept he believes is lacking in today’s transactional economy. Join Tom Fox and Nick Gallo as they delve deeper into these insights on this episode of the Report from Impact podcast.

 Highlights Include 

·      The impact of culture in M&A

·      The role of ethics in the workplace

·      A new generation in the workforce

 Resources 

Nick Gallo on LinkedIn

Ethico

ECI