Why Do Compliance Programs Fall Short of Expectations?

Follow Through and Continuous Improvement

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, […]