What are some common mistakes that compliance professionals make when communicating about compliance? Since 1991, when the US Sentencing Guidelines first addressed the importance of communication in tandem with formal compliance training, compliance officers have occasionally struggled with how frequently and in what ways to address compliance communication. In this episode, Eric talks about some common issues organizations have faced when considering the more informal side of efforts to educate and inform employees and other stakeholders about compliance risks and issues. Eric also focuses on ways organizations can address these common situations and how the recent the Department of Justice’s recent guidance, the Evaluation of Corporate Compliance Programs, and other standards effect communication requirements and expectations. Finally, Eric also offers some specific practical ideas for organizations to consider when addressing compliance communication efforts.
What are some strategies and options for the compliance officer that is aware of misconduct occurring at their organization? This can be one of the most complicated topics that a compliance officer can face. And there are not always a lot of good solutions. But what options should the compliance officer consider? And what should the compliance office expect from their organization? This week, Eric explores the answers to these questions.
When we think about third-party management, we often think of due diligence. The Department of Justice Fraud Section’s new compliance and ethics guidance, the Evaluation of Corporate Compliance Programs, only mentions due diligence one time. The Evaluation contemplates a holistic, ongoing approach to third-party management in which the process is integrated into other functions, such as procurement.
The new Department of Justice’s guidance, the Evaluation of Corporate Compliance Programs, discusses the “design and accessibility” of written standards, such as your code of conduct. Does this focus on “design” in particular mean that organizations should reconsider or review the use of interactivity for their code? What does the Department’s focus on “communication” and “evaluation” of written standards affect how an organizations evaluates and implements any interactive features? Eric discusses what the new focus on design and accessibility might mean and how organizations can address these expectations in their code of conduct review, revision and development processes.
How does the new Department of Justice’s new guidance, the Evaluation of Corporate Compliance Programs, from February 2017 approach the requirements for written standards, including code of conduct? Eric walks through three key takeaways from the Evaluation of Corporate Compliance Programs on how organizations should document and conduct their code of conduct development and review process. We also have Part One of a two part Special Interview with Alison Taylor of BSR.
As an alumni of Baylor University, Eric has been closely following the allegations that Baylor University violated its obligations under Title IX. Six months after his first episode looking at this issue, Baylor University, unfortunately, is still in the news. What’s going on? What lessons can compliance professionals learn from Baylor University and how this compliance failure has been handled?
Regents have provided a playbook of what not to do when responding to a compliance failure. From When looking at how Baylor University has handled this situation, Eric considers three key teaching moments. First, Baylor’s problems dispel any belief that private companies or private universities can handle these issues internally and without public scrutiny. Second, he considers how Baylor’s response continued to damage Baylor’s reputation and how reputational harm damages the University overall. Third, he talks about the importance of transparency.
At the end of the episode, Eric lays out some of the steps that Baylor University’s new president, Dr. Linda Livingstone, should take to repair the reputational harm and restore confidence in the University.
What’s the difference between compliance and corporate culture? Is there a difference? How do they work together? In this episode, Eric looks at how two airlines, United and Delta, responded recently to challenges they faced and how their responses speak to their corporate cultures. Both airlines faced operational failures. The juxtaposition of their responses are excellent teaching moments and examples that compliance professionals can give to demonstrate the relationship between compliance and corporate culture.
As Eric returns from the Society for Corporate Compliance & Ethics European Ethics & Compliance Institute in Prague, he shares the hot topics of discussion at the conference. He discusses his three main takeaways from the conference.
Just a few years ago, Europe was considered behind the United States in compliance and ethics. That is not the case today. Eric looks at three hot topics in compliance and ethics in Europe as he prepares to leave for the Society of Corporate Compliance and Ethics European Compliance & Ethics Institute in Prague this week.
When we are talking about risk assessment and the Evaluation of Corporate Compliance Programs, there are three areas to really focus on. First, the Evaluation considers how organizations create and use their methodology for risk assessment. Second, this new guidance focuses on how the data you gather informs the choices you make in your compliance…