In The Middle of It All: New Research on Middle Managers and Ethical Behavior, Part I of 2

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We are very, very pleased to have a special discussion over the next two weeks about some very interesting new research and data about managers and ethics. We will be interviewing the principal authors of a new article just published in October, titled “Middle Managers and Corruptive Routine Translation: The Social Production of Deceptive Performance”.…

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Revisiting Our 2017 Trend Predictions

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Closing the loop on some trends we thought might be important back in January of 2017. First, we all had (and still have) deregulation on our minds. So far, while there has been a lot of discussion about the possible effects of deregulation, it’s fair to say that compliance issues are still being driven by…

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What Do You Do To Overcome a Significant Cultural Issue?

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This time Eric addresses what to do in those extreme situations where there are significant or serious cultural issues. First, we talk about getting by-in and support of leadership for your efforts. It’s hard to imagine overcoming significant issues if there is no support from leadership in the organization. Buy-in also includes getting the operational…

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Recent US Department of Justice Commentary and the Impact on Compliance

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What does the Deputy Attorney General’s recent comments about various Department memorandum and informal statements mean for compliance and ethics. For more information on the DAG’s October statement, you can review this excellent commentary. The statement suggests that many of the DOJ memos discussing corporate prosecutions we are familiar with may be consolidated (or revoked).…

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Reflecting on the SCCE’s Compliance and Ethics Institute

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This time Eric reflects on the annual SCCE Compliance and Ethics Institute in Las Vegas. While there are certainly other compliance and ethics events, the size and scope of the CEI is impressive and we noted three themes this year that apply not to just CEI, but the profession in general. First, growth — and…

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Three Things To Know About Third-Party Risk

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Today Eric talks about third-party risks and some ideas for every organization to think about when thinking about third-party risk.

First, we encourage everyone to think outside the box and contemplate the actual third-party risks that their specific organization faces. We often think third-party risk just applies to organizations that operate overseas or have anti-corruption risks. Third-party risks are much broader and organizations should take time to consider it.

Second, Eric talks about how third parties are the “perfect storm” for risk. It’s hard to imagine any organization these days that doesn’t have third-party risk. Additionally, we talk a little about how third parties are logistically hard to monitor. Eric points out that despite these difficulties, organizations are liable for the actions taken on their behalf.

Third, there is a way to reasonable manage the risk organizations of all sizes and types face from third parties. Have a plan. Be consistent. Apply your limited resources based on a risk analysis. Guiding principles for due diligence include getting as much information about the third parties as you can, understanding the business rationale and establishing the ongoing relationship parameters.

Eric also talks a little about tiering or ranking risk. We list off several factors that you can consider when ranking the risk of a third party.

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Tone From the Top

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This time Eric talks about three practical areas to consider when evaluating and developing “tone from the top” at your organization. First, we examine what the expectations should be for the CEO or top executive of the organization. The CEO should be “present” in a real way and this can be measured by both the…

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Compliance & Ethics Institute Preview with SCCE’s Adam Turteltaub

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Adam Turteltaub

This week, we prepare to go to the annual SCCE CEI in Las Vegas. Recent events make the trip more somber, but we look forward to seeing old friends and meeting new ones. Eric speaks with SCCE’s Adam Turteltaub to discuss what’s new this year at the Compliance and Ethics Institute and some of the thought that goes into planning and organizing the annual event.

Eric also talks a little about the concept of “right action” and moving forward with your goals despite conflict.

It was a year ago that we launched Compliance Beat as we were preparing for the Institute. A big thank you to everyone out there that listens to us weekly. We hope to continue to provide interesting and useful content on compliance and ethics for years to come.

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What’s the ‘Bare Minimum’ Needed for Compliance? Part II

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What is the “bare minimum” an organization needs to have an effective compliance program?  Today we have part II of our discussion of what minimum requirements for an effective compliance and ethics program might be. Eric talks a little about the focus on organizational guidelines versus the Sentencing Guidelines as a whole. Eric also talks…

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What’s the ‘Bare Minimum’ Needed for Compliance? Part I

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ITUNES COVER

What is the “bare minimum” an organization needs to have an effective compliance program?  Is that even the right question?  Eric talks about a common inquiry that people often have about the “Seven Hallmarks” of the Sentencing Guidelines, and that is: what must we do? In Part I of a two-part series, Eric talks about…

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