Compliance Officer Liability after VW & Takata

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What does the flurry of indictments against individuals at Volkswagen and Takata tell us about compliance officer liability after the Yates Memo?  Eric revisits the impact of the Yates Memo on compliance officer liability with the news of these prosecutions. The Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9,…

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What are three ways to involve managers in your compliance & ethics program? & Three Questions with Gretchen Winters

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If you are looking for ways to involve your managers in your compliance and ethics program, three places to start are engaging managers in training, giving them tools to engage in regular communication about compliance and ethics issues, and helping build strong teams and good rapport with their direct reports.

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What can you do to prevent retaliation & encourage employees to report misconduct? & Three Questions with Che Hembrey

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In order to answer this question, it’s important to first look at the data on retaliation. In three different reports, two in 2012 and one in 2015, the Ethics and Compliance Initiative examined the percentage of employees that report witnessing misconduct. These reports found that 40% to 50%, or approximately four out of ten employees,…

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2017 Trends in Compliance & Ethics Special Edition

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What are going to be the overarching trends in compliance and ethics in 2017? In this episode, Eric talks about compliance and ethics program trends that will affect every company, no matter your size and no matter whether you are in a highly regulated space.

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Should you use interactive design for your code of conduct? & Three Questions with Ricardo Pellafone

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When determining whether to use an interactive design, be sure to spend some time thinking about these three questions: How do your stakeholders interact with your current code of conduct? What is your organization’s communication style? How do you maintain your code of conduct?

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Do we need to train our Board of Directors on compliance and ethics? & Three Questions with JoAnn Mahoney

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When training your Board of Directors, you should address the three pillars in board training: risk specific topic, regular review of the Board’s responsibility to oversee the compliance and ethics program and a comprehensive review of employees’ and other stakeholders’ code of conduct training.

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Compliance Failures & Crisis Management: What can we learn from Baylor University & Penn State?

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Sexual assault allegations rocked two prestigious university football programs, Penn State and Baylor University. Both universities took two different paths to addressing the underlying compliance, governance and risk problems that led to the scandals. Penn State embraced a transparent approach to addressing the problems. In contrast, Baylor’s Board of Regents have blocked stakeholders’ efforts to understand the root causes of their compliance failures.

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Does the Yates Memo increase my liability as a compliance officer? & Three Questions with Ted Banks

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The Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9, 2015, addresses individual liability for corporate wrongdoing. In the memo, the DAG Yates lays out new guidance to Department of Justice attorneys who are prosecuting individuals involved in corporate wrongdoing. When you review the data over the years preceding the…

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“What are the dos and don’ts of written compliance policies?” & Three Questions with Wesley Bizzell

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There are some key things to keep in mind when you are planning to update your standalone compliance and ethics policies. The types of stakeholders and subject-matter experts who you will have to consult with are wider and broader than the ones you consult with when rewriting your code of conduct. It will take planning to get them aligned with the end goal. Just as you would in a modern code of conduct, you need to pay attention to the language you use in your policies. Try to reduce jargon and have a conversational tone. Consider design and interactive learning aids where possible. Also, develop a template so that you have a consistent approach across your policies.

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“What are the key steps for effective assessment interviews?” & Three Questions with Kathleen Grilli

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As your organization approaches a regular assessment of your compliance and ethics program, consider whether you need to include personnel interviews as part of the process. Many organizations rely solely on benchmarking data and surveys to assess their programs.  Time constraints can often prevent a deeper dive into program effectiveness.  While not every regular assessment…

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