Tag: RCA

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Everything Compliance

Everything Compliance: Episode 143, The North to South Episode

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows.

In this episode, we have the quartet of Matt Kelly, Jonathan Marks, and Karen Moore; with host Tom Fox wearing a double hat as a commentator as well. We take up Root Cause Analysis, DEI questions in the Boeing monitorship, failures at TD Bank and a possible Caremark claim.

1. Matt Kelly takes a look into the commercial strategies which led to the compliance failures at TD Banks.  He rants about the Boston’s National Women’s Soccer League team (now deleted) advertising campaign announcing the new team with the tagline ‘too many balls’.

2. Jonathan Marks explains the differences in a Root Cause Analysis and investigations. He shouts out the WNBA and the person who solved the Golden Owl puzzle.

3. Karen Moore takes a deep dive into the district court’s request for more information on the impact of DEI on the Boeing monitorship. She rants about non-civility in the Supermarkets of America’s Parking Lots.

4. Tom Fox takes a look at the potential Caremark claim against TD Bank for both Directors and Officers failures in their duties. He shouts out to GOP dominated Texas Legislature for subpoenaing Robert Roberson for an appearance before the House, one day before his scheduled execution and the Texas Supreme Court for staying his execution until he could appear.

The members of the Everything Compliance are:

The host and producer, rantor (and sometime panelist) of Everything Compliance is Tom Fox the Voice of Compliance. He can be reached at tfox@tfoxlaw.com. Everything Compliance is a part of the award-winning Compliance Podcast Network.

Additional Resources:

1.     Jonathan Marks on Root Cause Analysis on LinkedIn.

2.     Matt Kelly on TD Bank’s Enforcement Action on Radical Compliance.

3.     Tom Fox on the potential Caremark claims in the TD Bank case on the Compliance Podcast Network blog.

 

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Compliance Tip of the Day

Compliance Tip of the Day: Lessons on Root Cause Analysis from John Deere

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.

Not only does the DOJ expect companies to perform a Root Cause Analysis during any investigation, but a RCA helps to identify systemic issues for remediation.

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Compliance Tip of the Day

Compliance Tip of the Day: Lesson from The John Deere FCPA Enforcement Action – Root Cause Analysis for Remediation

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.

Today, we review why a root cause analysis is the first step you should take before you begin the remediation of your compliance program.

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Sunday Book Review

Sunday Book Review: May 19, 2024 Books on Root Cause Analysis Edition

In the Sunday Book Review, Tom Fox considers books that would interest the compliance professional, the business executive, or anyone who might be curious.

It could be books about business, compliance, history, leadership, current events, or anything else that might interest me.

In today’s edition of the Sunday Book Review, we look at some of the top books on root cause analysis you should read.

  • The New Science of Fixing Things by David Hartshorne
  • The Root Cause Analysis Handbook by Max Ammerman
  • Root Cause Analysis: The Core of Problem Solving by Duke Okes
  • Root Cause Analysis: Improving Performance for the Bottom Line  by By Mark A. Latino, Robert J. Latino, and Kenneth C. Latino

For more information on Ethico and a free White Paper on ROI for your compliance program, click here.

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31 Days to More Effective Compliance Programs

Day 31 | Using a root cause analysis for remediation


The 2020 Update re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively in practice is the extent to which a company is able to conduct a thoughtful root cause analysis of misconduct and timely and appropriately remediate to address the root causes.”
It went on to state, what additional steps the company has taken “that demonstrate recognition of the seriousness of the misconduct, acceptance of responsibility for it, and the implementation of measures to reduce the risk of repetition of such misconduct, including measures to identify future risk”).”
The key is that after you have identified the causes of problems, consider the solutions that can be implemented by developing a logical approach, using data that already exists in the organization. Identify current and future needs for organizational improvement. Your solution should be a repeatable, step-by-step processes, in which one process can confirm the results of another. Focusing on the corrective measures of root causes is more effective than simply treating the symptoms of a problem or event and you will have a much more robust solution in place. This is because the solution(s) are more effective when accomplished through a systematic process with conclusions backed up by evidence.
When you step back and consider what the DOJ was trying to accomplish with its 2020 Update, it becomes clear what the DOJ expects from the compliance professional. Consider the structure of your compliance program and how it inter-relates to your company’s risk profile. When you have a compliance failure, use the root cause analysis to think about how each of the structural elements of your compliance program could impact how you manage and deal with that risk.
Three key takeaways:

  1. The key is objectivity and independence.
  2. The critical element is how did you use the information you developed in the root cause analysis?
  3. The key is that after you have identified the causes of problems, consider the solutions that can be implemented by developing a logical approach, using data that already exists in the organization.