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Business Integrity Innovations

Business Integrity Innovations: Collective Action Against Corruption: Insights from Pana Ratanabanangkoon

Business Integrity Innovations is brought to you by the Center for International Private Enterprise (CIPE) and the Compliance Podcast Network (CPN). This podcast is inspired by Ethics 1st, a multi-stakeholder initiative led by CIPE that creates pathways for accountable and sustainable investment in Africa. Companies can use Ethics 1st to standardize their business practices, develop sound corporate governance systems, and demonstrate their commitment to compliance and business ethics.

In this episode, Tom and Lola are joined by Pana Ratanabanangkoon, who has over 30 years of experience in the energy industry and is a key figure in the anti-corruption movement. Pana shares his journey from working with Shell in various countries to leading the Thai Collective Action Against Corruption (Thai CAC). He details the evolution of Thai CAC, highlighting its significant growth and innovative strategies in collective action, certification processes, and compliance. Pana also discusses establishing the International Collective Action Network (ICANN) to support similar initiatives globally. The conversation delves into the challenges and motivations driving anti-corruption efforts in the private sector and explores future trends, including the potential role of AI in enhancing compliance programs.

Key highlights:

  • Pana’s Professional Background
  • Role in Anti-Corruption Efforts
  • Evolution of Thai CAC
  • Challenges and Experiences
  • Future of Anti-Corruption Initiatives
  • Business Solutions to Corruption

Resources:

Pana Ratanabanangkoon on LinkedIn

CIPE

CIPE

Ethics 1st

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Everything Compliance

Everything Compliance: Episode 146, The Holiday Season Edition

Welcome to this Special Edition of Everything Compliance. In this episode, Matt Kelly, Jonathan Marks, Karen Woody, and Karen Moore examine various issues for compliance professionals under the incoming administration.

  1. Jonathan Marks discusses how deepfake videos facilitate fraud and how companies can combat this scourge. He shouts out to Miriam Chamani and her Voodoo Spiritual Temple.
  2. Karen Moore takes a deep dive into sustainability requirements in the EU and what these obligations mean for US companies under the second Trump administration. She shouts out to all the delivery folks this holiday season.
  3. Matt Kelly examines the DOGE initiative and its potential impact on compliance. He rants about the Pete Hegseth nomination and praises the South Korean people who opposed the presidential coup.
  4. Karen Woody examines what the new Trump administration may mean for the SEC in the future and rants about Time Magazine naming Donald Trump its Man of the Year.
  5. Tom Fox shouts out to the Shuffle Mamas.

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.

For more information on the Ethico Toolkit for Middle Managers, available at no charge by clicking here.

Check out the full 3-book series, The Compliance Kids on Amazon.com.

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Blog

FT Business Book of the Year, Alison Taylor and Higher Ground

The Financial Times (FT) and Schroders Business Book of the Year Award is the most prestigious accolade in business publishing, recognizing exceptional insight, research, and storytelling in books addressing current business, economic, and financial issues.  The FT Business Book of the Year Award highlights books that significantly impact the understanding of global business issues, often bringing complex topics like economic theory, corporate culture, innovation, and ethics to a wider audience. It serves as a quality benchmark in business publishing, with many past winners going on to influence policy, business practices, and public discourse.

The Financial Times’ reputation ensures that nominated books are taken seriously by readers, reviewers, and business leaders worldwide.  The FT Business Book of the Year Award draws attention to emerging trends and thought leadership in business, with topics often reflecting current global challenges. For example, recent winners have focused on climate change, economic inequality, corporate responsibility, and technology’s impact on society. Ultimately, the FT Business Book of the Year Award plays a significant role in shaping the business conversation by identifying the most relevant and impactful works that capture the challenges and dynamics of modern commerce. To make the Long List of nominees, a book was among 16 selected out of over 600 entries.

If you are in the compliance field, you are probably lucky enough to know one of this year’s Long List nominees–Alison Taylor, whose book, Higher Ground-How Business Can do the Right Thing in a Turbulent World, has provided a fresh dialogue on the evolving role of business ethics in corporate governance. Alison once gave me the moniker The Rock and Roll Compliance Blogger. But even more importantly, Alison has long contributed to and, in many ways, led the ongoing dialogue in the corporate compliance community on compliance and ethics and sustainability and ESG on the other. Her central thesis questions why these two fields, both concerned with promoting responsible corporate behavior, remain siloed and isolated. Higher Ground bridges this gap, providing corporate leaders a roadmap for fostering a more integrated approach to ethical business practices.

Taylor opens *Higher Ground* with a case study on Starbucks—a company widely regarded as a leader in corporate responsibility. Known for benefits like health insurance for part-time employees, Starbucks has long been a model of progressive labor practices. But recently, the coffee giant has faced substantial backlash over labor rights issues as employees pushed for unionization, highlighting a disconnect between corporate policies and ground-level employee sentiment.

This disconnect between corporate identity and stakeholder perception illustrates a significant point for Starbucks: being a “good” business isn’t a shield against reputational risks. Despite its robust ESG credentials, Starbucks has been mired in controversy, underscoring that even the most well-intentioned corporations may face criticism if stakeholders perceive a misalignment between professed values and on-the-ground realities. Taylor’s analysis reminds compliance professionals that reputation and stakeholder trust can be fragile and influenced by factors beyond traditional ESG metrics.

Overcoming the Trap of Overpromising in Corporate Purpose

Taylor’s argument extends to the challenge of corporate overpromising, a pitfall many organizations find themselves in when attempting to cater to the demands of diverse stakeholders. As she points out, recent trends have created a polarized landscape where companies are criticized from both sides—either for being too focused on social responsibility (often labeled as “woke” by critics) or for not doing enough. Navigating this space requires corporate leaders to communicate clearly and make decisions based on what is realistically achievable.

In Higher Ground, Taylor encourages leaders to avoid becoming trapped by unsustainable promises. Instead, she advocates for identifying one to three critical issues that align with the company’s long-term strategic goals. Prioritizing these issues allows organizations to make meaningful progress while maintaining their efforts across many fronts. For compliance professionals, this approach emphasizes the need to set realistic, measurable goals in alignment with an organization’s core values.

Moving from Rules-Based to Principles-Based Compliance

One of the most resonant themes in Higher Ground for compliance officers is Taylor’s call to shift from a rules-based to a principles-based approach to compliance. While rules and regulations are fundamental to compliance programs, they can fall short when organizations face nuanced ethical dilemmas. Principles-based compliance, which emphasizes ethical judgment and a strong moral compass, allows organizations to respond more effectively to complex situations that cannot be anticipated by rules alone.

Taylor argues that fostering an ethical culture requires more than drafting policies and procedures. It involves setting up systems where employees feel empowered to speak up and exercise sound judgment. Compliance leaders should aim to cultivate an environment where employees are encouraged to use their ethical instincts and are rewarded.

Addressing the Generational Shift in Corporate Expectations

As Taylor observes, today’s workforce spans five generations, each with its values, priorities, and expectations from corporate leadership. Millennials and GenZers highly value authenticity, transparency, and social impact. They are also more inclined to speak up on climate change and diversity, often pushing their employers to take public stances.

This shift presents both challenges and opportunities for compliance leaders. Younger generations’ desire for accountability and transparency aligns well with the goals of modern compliance programs, which are increasingly centered around creating ethical, transparent workplaces. However, the push for corporate responsibility requires careful management to ensure that public commitments align with internal practices. Taylor emphasizes the need for open communication, a willingness to address employee concerns, and a commitment to genuine stakeholder engagement.

Balancing Impact and Purpose

Taylor posits that a meaningful corporate purpose is inseparable from measurable impact. While “purpose” has become a popular corporate buzzword, she cautions that it remains little more than marketing rhetoric without concrete actions and results. For companies to build true stakeholder trust, they must put impact at the core of their purpose, recognizing both their operations’ positive and negative effects on society.

This perspective offers valuable guidance for compliance leaders. Compliance programs must go beyond box-ticking exercises and contribute meaningfully to the organization’s ethical culture. By making decisions based on their actual impact on employees, customers, and the broader community, compliance teams can help build a more resilient and trustworthy corporate reputation.

Practical Steps for Building an Ethical, Responsible Organization

Higher Ground provides practical insights for organizations seeking to improve their ethical culture and align with evolving stakeholder expectations. Some actionable steps for compliance professionals include:

  1. Set Priorities. Instead of meeting every stakeholder’s demand, focus on one to three key issues where the organization can make a meaningful impact.
  2. Encourage Open Dialogue. Foster a culture of transparency where employees feel comfortable voicing ethical concerns, even when these concerns challenge leadership decisions.
  3. Embrace a Principles-Based Approach. Shift the focus from strict rule adherence to fostering ethical judgment and principled decision-making across the organization.
  4. Align Corporate Promises with Impact. Ensure public commitments are backed by actionable, measurable goals reflecting the organization’s values and capabilities.
  5. Engage Multiple Generations. Recognize each generation’s unique values in the workforce and create an inclusive environment that respects diverse perspectives on social and environmental issues.

In Higher Ground, Alison Taylor offers a comprehensive exploration of how businesses can bridge the gap between ethics and sustainability, building trust and integrity. By examining the role of corporations through the lens of stakeholder expectations, she challenges leaders to redefine success beyond shareholder value. Her call for a more nuanced approach to business ethics resonates strongly in today’s rapidly evolving regulatory and social landscape.

For compliance professionals, Taylor’s work is a timely reminder of the importance of staying connected to the broader organizational mission and ensuring that ethics programs are integrated into every facet of the business. Whether setting clear priorities, encouraging open dialogue, or embracing principles-based compliance, Higher Ground provides a roadmap for leaders committed to building ethical organizations in the 21st century.

If you want to explore these themes in more depth, please check out Higher Ground and join the thoughtful conversation that Taylor has started. Given the advent of the second Trump Administration, these discussions have taken on a new urgency.

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Blog

Navigating the New Ethical Landscape: Higher Ground with Alison Taylor

On a recent edition of the SBR Authors Podcast, I recently had the opportunity to visit with Alison Taylor, a renowned figure in the compliance and ethics community, about her new book,  Higher Ground. Alison has one of the most diverse professional backgrounds of any person I know in compliance. She is a Clinical Professor and Executive Director of Ethical Systems at NYU Stern School of Business. This blog delves into the key points discussed during the podcast, shedding light on the evolving landscape of business ethics and the challenges of maintaining an ethical culture today.

A series of intriguing transitions mark Taylor’s career. She began her professional journey with editing, consulting, and political risk roles before spending twelve years in corporate investigations. This period saw her working with Control Risks, leading investigations across the Middle East, Africa, and the Americas. Her work included due diligence, FCPA investigations, and background checks when FCPA enforcement gained significant momentum.

In 2015, Alison transitioned to the field of sustainability. She joined a non-profit organization to consult with multinational corporations on climate change, human rights, and corporate responsibility issues. Since late 2019, she has been part of the faculty at NYU, first running a think tank called Ethical Systems and now adding on as a full-time faculty member. Alison’s broad experience across different business ethics and sustainability domains gave her a unique perspective, ultimately leading to her book, Higher Ground.

Taylor’s shift from corporate investigations to sustainability and ESG highlighted a fascinating disconnect. While both fields aimed to define what it means to be a good and ethical business, they approached the issue very differently. The language, concepts, and philosophical foundations varied significantly between the two. This disconnect inspired her to explore why these two disciplines, despite their common goals, needed to communicate more effectively with each other.

Higher Ground aims to bridge this gap. Taylor sought to provide clarity for those grappling with questions about business ethics and the role of businesses in society, especially for senior leaders who may need deep expertise in both compliance and sustainability. The book is designed to guide readers through the complexities of these topics, offering a path forward in an increasingly chaotic business environment.

Writing a book is challenging, and Taylor’s experience was no different. She initially thought of herself as not a morning person but quickly realized that her most productive writing time was in the early hours of the day. She found that she could only manage about three to four hours of effective writing each day, after which her productivity declined. This disciplined approach helped her balance writing the book with her full-time job and teaching responsibilities.

The process took about two years and involved multiple rewrites and restructures. Taylor described it as an emotional roller coaster, with periods of satisfaction followed by moments of doubt. Despite the challenges, she completed the book, providing valuable insights into the evolving field of business ethics.

Taylor chose to open her book with the story of Starbucks and its labor rights issues. Despite being a leader in sustainability and labor rights by many measures, Starbucks faced significant reputational challenges over its stance on unionization. This example illustrated how a company could excel in ESG metrics yet still suffer reputational damage due to specific strategic errors.

Starbucks, known for its favorable treatment of employees and leadership in sustainability, faced backlash from students, investors, and employees over its anti-union stance. This contradiction highlighted the complexities of maintaining an ethical reputation. Alison used this case to demonstrate that reputational risk is not a linear accountability mechanism but more like a funhouse mirror, reflecting the unpredictable nature of stakeholder perceptions.

Taylor emphasized the importance of honesty and focus in building stakeholder trust. In today’s polarized environment, companies are often caught between unrealistic expectations from the left and the right. She argued that companies need to be more honest about what they can and cannot achieve, focusing on a few strategically important issues rather than trying to address every concern.

She suggested that companies conduct materiality assessments to identify the most relevant issues and concentrate on these areas. Companies can build more sustainable trust with their stakeholders by aligning their actions with their strategic priorities and being transparent about their limitations.

Taylor discussed the importance of aligning rules and policies with the broader business culture. She noted that compliance efforts often fail when there is a disconnect between stated values and actual behavior or when there are different rules for senior leaders and other employees. Successful compliance programs require the support and engagement of the entire organization, not just the compliance department.

She also highlighted the need for compliance and ethics teams to work closely with other parts of the business. By integrating ethical considerations into the overall business strategy, companies can create a more coherent and practical approach to compliance and corporate responsibility.

With five generations now present in the workplace, Alison explored the challenges and opportunities of engaging a diverse workforce. Younger employees are more likely to be concerned with climate change and diversity and expect authenticity and accountability from their employers.

Taylor also noted that younger employees often push for change, while resistance is more common at the senior levels. Companies need to find ways to harness this energy and passion and use it to drive positive change. This involves creating mechanisms for employee voice and encouraging open debate about ethical issues.

Alison Taylor’s Higher Ground provides a thoughtful and comprehensive guide to navigating the complex world of business ethics and sustainability. Her insights from a rich and varied career offer valuable lessons for companies striving to build trust and maintain ethical cultures in an ever-changing landscape. By focusing on strategic priorities, aligning actions with values, and engaging a diverse workforce, businesses can rise to the challenges of today’s ethical environment and positively impact society.

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Compliance Into the Weeds

Compliance into the Weeds: Sustainability and Managing 3rd Party Risk

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 more fully explore a subject.

Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds!

In this episode, Tom Fox and Matt Kelly take a deep dive into a recent report by Prevalent on Third Party Risk Management in 2024 and Microsoft’s 2024 Environmental Sustainability Report.

Tom and Matt discuss the challenge companies face in aligning their sustainability goals with their supply chain management. They question whether sustainability functions within a company have the authority to influence supply chain decisions, such as rejecting suppliers that do not meet sustainability criteria.

We discuss the  Microsoft Report, noting that while the company acknowledges it has not yet achieved the ability to reject non-compliant suppliers, it suggests a target of improvement by 2030. The core issue highlighted is whether sustainability initiatives will have significant influence over supply chain decisions in the future. 

Key Highlights:

  • Intersection of Supply Chain Risk Management and Sustainability
  • The Role of Sustainability in Supply Chain Decisions
  • Microsoft’s Journey Towards Sustainable Supply Chain Management
  • The Energy Industry Model

Resources:

Matt on Radical Compliance

Tom 

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The ESG Report

The ESG Report – Shireen Muhiudeen: How Sustainability Impacts Businesses

The ESG Report podcast is hosted by Tom Fox. Looking for innovative solutions to tackle climate change? Look no further than the ESG Report!

In this episode, Tom speaks with Shireen Muhiudeen, a fund manager who believes sustainability is a good business investment.

Shireen Muhiudeen is a well-established fund manager with over 30 years of experience in the equities and private equity domains in Southeast Asia and has been the leader of a firm for two decades.

From her extensive background, Shireen Muhiudeen has formed the perspective that ESG (Environmental, Social, and Governance) factors and sustainability are integral considerations for any fund manager. She underscores the significance of companies being both socially responsible and environmentally conscious, advocating for a long-term approach that takes into account the impact on communities and the environment.

Following the COVID-19 pandemic, she acknowledges the challenges businesses face when resources are scarce and survival becomes a priority over sustainability. Despite these challenges, she emphasizes the need for awareness, adaptability, and a balanced approach to addressing risk, demonstrating her belief in the importance of sustainable practices for long-term success.

Key Highlights:

  • Cost-Effective ESG Implementation Strategies
  • Fair Treatment of Migrant Labor in Business
  • Future-Focused Investing: ESG Integration and Responsibility
  • Digital Age Stakeholder Engagement Landscape

Resources:

Shireen Muhiudeen on LinkedIn

Corston-Smith Investments

We Are All Stakeholders

 

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2 Gurus Talk Compliance

2 Gurus Talk Compliance – Episode 23 — The Sustainability Edition

What happens when two top compliance commentators get together? They talk about compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s episode! In this episode, Tom and Kristy take on a wide variety of compliance related topics.

In the ever-evolving world of regulatory compliance and risk management, challenges are constant, and strategies must be dynamic. Tom highlights the focus on the Tesla Board, celebrates the OECD at 25, bemoans New Zealand’s drop in the TI-CPI, reviews the HP acquisition of Autonomy and looks at the differences in Binance and FTX enforcement.  Kristy highlights the slave labor allegations, EU sustainability law, the ease of whistleblower restrictions, the EU and AI, and checks in on Florida Woman. Join Tom Fox and Kristy Grant-Hart as they delve deeper into these issues in this episode of the 2 Gurus Talk Compliance podcast.

Topics Discussed:

1.     Chinese Slave Labor Allegations Hold Up VW’s Audi, Porsche, and Bentley Vehicles in U.S. Ports (MotorTrend)

2.     EU Corporate Sustainability Due Diligence Law Most Likely Dead, For Now (Forbes)

3.     US Supreme Court’s UBS case makes it easier for whistleblowers to win suits (Reuters)

4.     How EU AI Act May Accelerate Compliance Regime for U.S. Enterprises (WSJ)

5.     The Tesla Board Chair is under scrutiny for oversight of the company.  (NYT)

6.     A tale of 2 corps: Binance and FTX. (Reuters)

7.     OECD at 25.  (The Hill)

8.     No DD, no problem as HP seeks $4bn from Mike Lynch.  (Bloomberg)

9.     New Zealand drops to No. 3 on TI-CPI. (The Conversation)

10.  Woman swipes $1.5 million and splurges on flights, Carnival cruises, Florida cops say (Yahoo)

Resources 

Kristy Grant-Hart on LinkedIn

Spark Consulting

Tom 

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Sustainability

Sustainability: The Business Opportunity of The 21st Century – The Rebuilding of Ukraine

Are you ready to take on the business opportunity of the 21st century? We are at a moment of enormous global change and even greater business opportunity. Climate change is the single biggest commercial opportunity of our time. In this podcast, Tom Fox and sustainability guru Richard Blundell explore the opportunities open to businesses that embrace sustainability from a business perspective. Find out why sustainability is the greatest opportunity of the 21st century and how you can prepare your business to take advantage of this unprecedented global opportunity.

Ukraine’s transition to renewable energy and its focus on cybersecurity is a fascinating topic, as the country is uniquely positioned to rebuild its energy infrastructure in a sustainable way and become a pioneer in green reconstruction. Tom Fox, with his emphasis on the potential of decentralization and distributed energy systems, sees Ukraine’s transition as an opportunity for the country to address its environmental and energy challenges while also positioning itself as a leader in sustainability. Richard Blundell, on the other hand, highlights the importance of learning from past failures and sees Ukraine’s commitment to a 2030 target of 50% renewables and 50% nuclear energy as crucial for national security and climate resilience. Both experts believe that Ukraine’s focus on cybersecurity education can position the country as a leader in providing cyber-related services. Join Tom Fox and Richard Blundell on this episode of Sustainability: The Business Opportunity of the 21st Century as they delve deeper into Ukraine’s transition to renewable energy and its focus on cybersecurity.

Key Highlights:

  • Transitioning to Rooftop Solar Panels for Improved Air Quality
  • Reimagining Ukraine’s Energy Infrastructure for Sustainability
  • Building a Green and Prosperous Future
  • Ukraine’s Sustainable Future: Zelensky’s Anti-Corruption Leadership
  • The Evolving Role of Cybersecurity in Future Conflicts

Resources:

Richard Blundell

 

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Sustainability

Sustainability: The Business Opportunity of The 21st Century – Episode 7, COP28

Are you ready to take on the business opportunity of the 21st century? We are at a moment of enormous global change and even greater business opportunity. Climate change is the single, biggest commercial opportunity of our time. In this podcast, Tom Fox and Sustainability guru Richard Blundell explore the opportunities open to businesses that embrace sustainability from the business perspective. Find out why sustainability is the greatest opportunity of the 21st century and you can prepare your business to take advantage of the unprecedented global opportunity.

In this episode, Tom Fox and Richard Blundell discuss the COP28 climate summit and its significance. They explore the goals of COP28, including the targets for reducing carbon emissions and the need for a loss and damage fund. They also discuss the accusations against the conference chair and the energy industry’s role in the transition to a greener future. The conversation highlights the challenges of meeting climate change commitments and the fear of apathy and excuses. Overall, the episode provides insights into the current state of climate action and the potential outcomes of COP28.

Key Highlights

  • COP28 is the 28th conference of parties on the issue of climate change, where countries discuss their performance in meeting emission reduction targets.
  • The loss and damage fund, aimed at supporting the transition to a lower carbon economy and compensating for climate-related damages, is a critical topic of discussion at COP28.
  • The energy industry has the knowledge and resources to play a significant role in the transition to renewable energy, but the leadership’s lack of interest and influence on policy pose challenges.
  • There is a concern that COP28 may result in apathy and excuses rather than meaningful action to address climate change.

Resources:

Richard Blundell

Tom Fox

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Daily Compliance News

Daily Compliance News: November 10, 2023 – The €14BN Question 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.

Stories we are following in today’s edition:

  • Delta cutting carbon footprint. (WSJ)
  • Will Apple pay $23BN tax in Ireland? (BBC)
  • Altice France is now under investigation. (Bloomberg)
  • Corruption still clouds Ukraine’s rebuild. (WSJ)