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.
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,…
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.
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?
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.
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.
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…
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.
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…
Where did Wells Fargo go wrong? “Tone from the top” is an often used phrase in the compliance and ethics space. But as the Wells Fargo allegations show us, tone from the top isn’t always enough to ensure that employees on the ground act ethically. In this special edition episode, Eric discusses who defines corporate culture and explains the importance of tone from the middle and how to create it. Eric and the CEO and Chairman of Old National Bancorp discuss how ONB creates and maintains its award-winning corporate culture.