Who Should Be Involved in a Code of Conduct Revision Project?

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In this episode Eric delves in a little deeper on a common question: who should be involved in a code of conduct project? Of course this depends a lot on what kind of project is being undertaken. Should you revise internally or bring in an outside team? What resources are available to your organization to…

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Is It Good To Be a “Famous” Compliance Officer?

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Interesting doings at the Department of Justice, and other recent issues have brought forward the notion of how valuable (or not) is it for an organization’s compliance officer to be “famous” or have a high profile in (or outside) the organization. Compliance officers want to market and communicate about their programs, of course, but what…

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Do The Sentencing Guidelines Matter Anymore?

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Recently we’ve seen more activity from the Department of Justice (Fraud Section) and other regulators both in the United States and internationally that address compliance and ethics program standards and effectiveness. One topic that’s come up informally in some conversations is whether the Sentencing Guidelines still hold a central role in defining “effectiveness” for a…

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Tips for Compliance and Ethics Program Incentives

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Since incentives were first introduced in the Sentencing Guidelines there has been little guidance about what exactly make up incentives for compliance. It’s also probably no surprise that one of the most underdeveloped parts of many compliance and ethics programs is the application of incentives. In this episode Eric talks about some practical things organizations…

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Using the Web: Should You Have a Web-Based Code of Conduct?

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Should you have a web-based code of conduct? A common question that many organizations have when they are updating their code of conduct is should the code be a web-based document? If not, how might an organization use both internal and external-facing web resources? Eric has some ideas about adapting the code, and code content,…

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Keeping Compliance Front of Mind

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This time Eric talks about different ways compliance and ethics personnel can help keep the program and an ethical culture front of mind. Eric discusses how you can leverage slower times (often in the summer) to conduct site visits and otherwise engage in outreach. We also provide some practical examples of engagement activities to try…

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Three More Ways to Involve Managers in Compliance and Ethics

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In this episode Eric revisits a topic that is front-of-mind for many these days: involving managers in compliance. Eric discusses how research has shown involving the middle can improve concerns around retaliation and positively impact the culture of the organization. One way to better involve the middle is to make sure managers are armed with…

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Compliance Communication Failures

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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.

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Misconduct: Options (& Responsibilities) for Compliance Officers & Three Questions with Garin Bergman

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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.

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What does DOJ’s new guidance say about third-party risk? & Three Questions with Tedrick Housh

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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.

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