Here you can find all of our articles on compliance and ethics. These pieces are written by a range of Compliance experts and cover a broad range of topics.
While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
Attending SCCE conferences is always a source of insights and new information. In these conferences I have seen quite a bit of focus on data analytics, and deservedly so. DOJ’s Criminal and Antitrust Divisions are both making it clear that they expect an effective compliance program to use data analytics.
The first time I saw Kristy Grant-Hart she put on a show about magic compliance dust and then brought the audience to reality by breaking the news that there is no such magic dust.
In our years of assessing compliance and ethics (C&E) programs, my partner Jeff Kaplan and I have pinpointed several key attributes that we consider essential to an effective program, including independence, authority, reach, access, and resources.
ISO 37001 has been quite controversial. Some have hailed it as a tremendous step forward in fighting corruption and calling for companies to pursue the certification. Others have denounced it as meaningless…
I confess to going a little holiday crazy starting in November. In the old days, I took great pleasure in presenting a special gift to each of my clients – something that was meaningful and celebrated the work and relationship we shared. About fifteen years ago, a client’s office sent the gift back to me. The gift wasn’t extravagant, but it violated the company’s strict rule against the compliance team’s accepting any gifts from vendors.
Over the years I have heard the Sentencing Guidelines standards erroneously dismissed as using an outdated “command and control” approach. The Guidelines come from an admittedly odd place , but they are far from being either legalistic or based on command and control. Anyone who takes the time to read them can see what they are: directions on how to apply management steps to achieve compliance in organizations.
Recent years have seen a fervent pitch toward using big data to determine where to focus on compliance and ethics programs and whether the programs are actually working. Guidance from the US Department of Justice, for example, makes it clear that if programs are to be credited, they need to engage in data analytics.
A large group of compliance professionals gathered in New York and virtually on October 30 and 31 to attend PLI’s Advanced Compliance and Ethics conference.
How do you convince management to implement a strong compliance program? There may be two different schools of thought on this: economic, and let’s say, moral.
Picture this. It is your first day on the job at a construction company. You are told where the work is being done and told to go there today and start working. You have had no training. You have never even been on a construction site. It would be too dangerous and a safety hazard for all. So you think this cannot happen?
For those just getting started with compliance risk assessments, the KISS approach can be invaluable. And by KISS, I mean “Keep it Simple with Spreadsheets.”