Tag: LRN

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FCPA Compliance Report

Susan Divers on the LRN Ethics & Compliance Program Effectiveness Report


In this episode of the FCPA Compliance Report, I am joined Susan Divers, Director of Thought Leadership at LRN. We discuss recently released LRN Ethics & Compliance Program Effectiveness Report. Highlights in include:

  • What is the LRN Ethics & Compliance Program Effectiveness Report?
  • What does it measure?
  • How is it generated?
  • Why is culture so critical?
  • What are the values in values?
  • What is LRN’s High Performance Premium?
  • What are the roles of managers and leaders?
  • What are the keys to effective training?
  • What will the new normal for compliance programs look like going forward?
  • The issue of culture and values down the road into 2025 and beyond.

Resources
Susan Divers
LRN Ethics & Compliance Program Effectiveness Report

Categories
Corruption, Crime and Compliance

Episode 225 – Interview of Susan Divers, LRN Senior Advisor


Susan Divers, LRN Senior Advisor, reviews LRN’s 2022 Ethics and Compliance Program Effectiveness Report. LRN conducts an annual Ethics, and Compliance Program Effectiveness Report (“LRN Report”) th (https://pages.lrn.com/2022-pei-report)at is a must-read for business leaders, managers, investors, compliance professionals, and other stakeholders. LRN’s annual report has addressed key issues surrounding the impact of the COVID-19 pandemic on companies and ethics and compliance programs.

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This Week in FCPA

Episode 289 – the Brady Retires edition

 
As the GOAT of pro football, Tom Brady retires, Brian Flores sues the NFL and the Bengals/Rams make the Super Bowl, Tom and Jay are back look at some of the week’s top compliance and ethics stories this week in the Brady Retires edition. 
Stories

  1. DOJ issues first Opinion Release of 2022. DOJ website. Tom in FCPA Compliance and Ethics Blog. Bill Steinman in the FCPA Blog.
  2. Do BODs have unrealistic expectations on compliance? Dick Cassin explores in the FCPA Blog.
  3. KPMG mislead FRC through forged docs. Risk and Compliance Platform Europe.
  4. LRN releases 2022 Program Effectiveness Report. Download report here. Matt Kelly in Radical Compliance.
  5. A ‘how-to’ on remediating. The HeadSpin enforcement action. Tom in FCPA Compliance and Ethics Blog. Aaron Nicodemus in Compliance Week. (sub req’d)
  6. Learning to scale up ethically. Hemant Taneja in CCI.
  7. Why compliance should lead ESG. Carrie Penman in Ethics and Compliance Matters.
  8. The Boardroom agenda in 2022. Deloitte in Harvard Law School forum on Corporate Governance.
  9. Changes in antitrust enforcement and its impact on compliance. Mike Volkov, Matt Kelly and Tom in Compliance into the Weeds. Mike Volkov with a 3-part blog series in Corruption Crime and Compliance.
  10. Unclear values can lead to unethical behavior. Brett Beasley in Center for Ethical Leadership.

 Podcasts and More

  1. In February on The Compliance Life, I visit with Ellen Smith, a former Director of Trade Compliance who recently started her own consulting firm. In Part 1, she discussed her academic background and early professional career.
  2. Aly McDevitt with a multipart series in Compliance Week on the end-to-end story of a ransomware attack. Here more about the series on this month’s edition of From the Editor’s Desk, with Tom and Dave Lefort. A subscription is required but Compliance Week is running a membership special of $199 for the year. Use Promo Code RNSM199. For information and details click here.
  3. CCI releases new e-book from Tom “FCPA 2021 Year in Review”. Available free from CCI.
  4. Trial of the Century-the Enron Trial. This week, Tom premiered a 5-part podcast series on the Enron Trial with Loren Steffy, who covered the trial for the Houston Chronicle. In Part 1, run up to the trial. In Part 2, the trial begins. In Part 3, the star witnesses and key testimony. In Part 4, the Verdict comes in. In Part 5, what did it all mean. It is be available on the Compliance Podcast Network, Megaphone, iTunes, Spotify and all other top podcast platforms.
  5. Looking for a quick daily bite of trade compliance? Check out the Compliance Kitchen with Silvia Surman, who gives a short 3-5 minute update on one trade compliance topic each day. On the Compliance Podcast Network.

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.

Categories
FCPA Compliance Report

Susan Divers on LRN’s 2020 Compliance Program Effectiveness Report


In the Episode, I visit with Susan Divers, Senior Executive at LRN. Susan is one of the leaders of the LNR team which annually produces the Program Effectiveness Report. The 2020 version has been released. We review its key findings and insights as well as the LRN Program Effectiveness Index. Finally, we conclude with a key theme of the Report and discuss why it is such an insight for the compliance professional.
Some of the highlights include:

  • What is the 2020 Program Effectiveness Report?
  • Why does LRN release this report annually?
  • This year’s report has even more importance and urgency but we had ethical failures which caused loss of life over the past year as well?
  • What were the overview of key insights?
  • What are some of the key reasons ethical scandals occur?
  • What is the Program Effectiveness Index (PEI) and what does it tell us this year?
  • What are the 5 elements of an ethical culture?
  • One of the key themes I took away from this year’s Report is the interconnectedness of compliance program elements.

Download and read the 2020 Program Effectiveness Report here. For more information on LRN, click here.LRN
 

Categories
Across the Board

Across the Board – Episode 1: What’s the Tone at the Very Top

In this special 5-part podcast series, I visit with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 1 we introduce the topic of what’s the tone at the very top of your organization. Some of the highlights from the podcast include:

  • What’s the role of the Board around compliance and ethics?
  • Why is it important for the Board to actively oversee a C&E program?
  • What is the biggest disconnect between the BOD and the compliance function?
  • Board members should think of compliance as beyond FCPA and Sarbanes-Oxley, yet there understanding is members’ fuzzy at best.
  • Board members understand what auditors do, but they often do not understand compliance enough to ask intelligent questions.”

Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

Categories
Across the Board

Across the Board – Episode 3: Not Enough Time/Not Enough Depth

In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 3, we consider many CECO’s concern that Boards do not dedicate sufficient time and priority to compliance nor go into sufficient depth into compliance programs and potential outcomes . Some of the highlights from the podcast include:

  • Why don’t Boards put in more time around E&C programs?
  • Why is compliance often the last item on the Board agenda and equally as often, left off for later?
  • CECOs want to be challenged by their Boards but often are not.
  • Does your Board have a compliance game plan?
  • Why don’t BODs go deeper into E&C programs? How would they do so?
  • Are Boards even asking the right questions?

Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

Categories
Across the Board

Across the Board – Episode 5: The Road Ahead

Over this special 5-part podcast series, I have visited with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In this fifth and final episode, we look at the road ahead. The White Paper stated, “Over time, the gulf between CECOs and boards should be bridgeable. We believe the bridge should be built quickly. The sooner that CECOs have the board’s ear – and that directors are fully aware of what CECOs and the initiatives they lead can bring to the table –the stronger and more resilient their companies will be.
Some of the highlights from the podcast include:

  • What practical steps should be taken to engage the board more actively and effectively in ethics and compliance oversight?
  1. More time, higher priority, stronger signals from boards in ethics and compliance oversight.
  2. Boards need to question whether ethics and compliance are genuinely integral to business operations.
  3. Elevate the CECO and establish direct and confidential reporting lines?
  • What lays on the road ahead?

Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

Categories
Across the Board

Across the Board – Episode 2: BOD Understanding and the Game Plan

In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We take a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 2, we consider the average Board of Director’s knowledge of compliance and your game plan going forward. Some of the highlights from the podcast include:

  • Why don’t Boards have a better understanding of the compliance function within their organization?
  • Why do BOD’s have such little knowledge of the CECO role?
  • Why does the BOD tend to focus on what has passed rather forward looking?
  • Does your Board have a compliance game plan?
  • Why does a BOD need to develop a framework for discussing, evaluating, and measuring ethics and compliance?
  • Why should BODs relate ethics and compliance to their companies’ core strategy and be able to have a sufficient point of view to guide and oversee it?

Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.

Categories
Across the Board

Across the Board – Episode 4: Metrics and Senior Management

In this special 5-part podcast series, I am visiting with David Greenberg, Special Advisor at LRN. We are taking a deep dive into the LRN White Paper entitled, “What’s the Tone at the Very Top: Board and Compliance: The Role of Boards in Overseeing Corporate Ethics & Compliance”. In this podcast series we explore the white paper in depth and provide the Chief Compliance Officer and compliance practitioner with succinct and practical tips for educating, dealing with and reporting to a Board of Directors. In Episode 4, we look metrics which a BOD should consider and how a Board should oversee senior management around ethics, compliance and culture.
Some of the highlights from the podcast include:

  • CECOs want their boards will send stronger signals to executive management about the importance of embedding ethics and compliance in the company’s business.
  • CECOs want boards to hold management more accountable for ethics and compliance
  • A BOD should ask management ‘What have you done to assure compliance. Show me.’
  • Why should a Board be concerned about metrics around culture?
  • What measures should a Board employ for culture and ethics?

Check out the LRN White Paper What’s the Tone at the Very Top: Board and Compliance: the Role of Boards in Overseeing Corporate Ethics & Complianceby clicking here.