Why Do Compliance Programs Fall Short of Expectations?
The Challenge Organizations are making significant investments in their ethics and compliance programs. Risk assessments, policies, training, disclosures, whistleblower hotlines, third party due diligence, surveys, audits, and assessments. They all contribute to an effective program. Yet, in our day-to-day interactions with Chief Compliance Officers, we have identified a common reason why programs often fail to […]
Closing the Disclosure “Gap” – Why Annual is not Enough
The Challenge Many organizations rely upon an annual certification and disclosure process to prompt employees to disclose actual or potential conflicts of interest. That is a problem. How are you closing the disclosure “gap”? Behavioral psychology teaches us that to increase compliance and get maximum impact out of our disclosure process, the disclosure should be […]
Gifts, Travel and Entertainment Disclosures — Why now?
Covid-19 has significantly reduced business travel and entertainment requests. So, why is now the perfect time to revisit your Gifts, Travel and Entertainment Disclosure process? The reason is simple… Change is easier when the amount of activity is lower. You wouldn’t change your accounting system in the midst of a year-end close, would you? Gift, […]
Exit Surveys for Ethics and Compliance – A Missed Opportunity?
Risk assessments are one of the foundational elements of an effective ethics and compliance program
Why Data and Technology are at the Center of the Revised DOJ Guidance
One thing is for certain – the DOJ has placed the use of technology and access to data at the center of their evaluation criteria
Summary of US DOJ’s Evaluation of Corporate Compliance Programs Revisions June 2020
The Department of Justice (DOJ) released Revised Guidance of Evaluation of Corporate Compliance Programs
US DOJ Evaluation of Corporate Compliance Programs — June 2020 Update Redline
This redlined version of the US DOJ’s Evaluation of Corporate Compliance Programs revised guidance shows
Conflicts of Interest: 7 Best Practices for Implementing a Successful Disclosure Process
You don’t need to look any further than the headlines to find the latest scandals involving conflicts of interest and . . .
Now More than Ever: Simple and Effective Risk Assessments
Risk assessments are one of the foundational elements of an effective ethics and compliance program
Can Ethical Culture Be Audited, Not Just Measured?
Can ethical culture be audited? That’s the question we recently received from the internal audit department at a Fortune 250