Search results for: policies and procedures
Trump, the Coup, and Corporate Ethics
Corporate America might be hoping that the difficult issues raised by President Trump’s attempted coup this week and the remaining days of his term will somehow pass them by. Too bad. What Trump has unleashed isn’t something businesses will be able to avoid. In several practical ways, dealing with Trump and his minions — both…
Read MoreEthics and Employee Surveillance
We have an interesting bit of research for compliance officers’ consideration today, exploring how companies can implement surveillance of employees working from home in a useful manner. Taking an ethical approach to the endeavor seems to be a key ingredient for success. The findings were reported in the MIT Sloan Management Review last week. Researchers…
Read MoreGoldman Sachs, FCPA, and Internal Controls
Now that we’ve all had the weekend to contemplate the massive Goldman Sachs FCPA enforcement action from last week (because that’s how we all spend our free time, right?), let’s return to an issue that’s been on my mind since the settlement was announced. How does a company strengthen an internal control, when that control…
Read MoreCampaign Finance and Corporate Compliance
We circle back today to postmaster general Louis DeJoy, who stands accused of pressuring employees in the 2010s to make political donations to his preferred Republican candidates. That’s a felony violation of campaign finance laws, and a fascinating glimpse of a compliance risk that can catch companies unprepared. DeJoy, you might recall, is already under…
Read MoreCompliance Improvements and Internal Controls
Now that we’ve all had a few weeks to sit with the latest Justice Department guidance about effective corporate compliance programs, let’s consider the next logical question. What must compliance officers be able to do, to deliver what this guidance wants to see? That’s been on my mind for two weeks, because these updates emphasize…
Read MoreSmithfield Foods and Covid-19 Controls
Businesses still struggle every day to maintain some semblance of successful operations during the Covid-19 crisis, and that struggle is about to get more challenging as countries around the world begin lifting lockdowns and re-opening economic activity as soon as this week. So what does that mean for corporate compliance programs? What are the policy…
Read MoreInternal Control and Reg FD Fails
The Securities and Exchange Commission has fined a Florida pharmaceutical firm $200,000 for violating Regulation Fair Disclosure — an offense we don’t see too often in compliance land, and therefore offers a good glimpse into the control failures that might lead to this sort of trouble. The company, TherapeuticsMD, develops hormone therapies to help with…
Read MoreDealers, Drugs, and FCPA Insight
I always welcome questions from compliance and audit professionals, and the following came to me last week: “What type of third party falls under ‘dealer’ for FCPA purposes?” The compliance officer who posed this question works at a company under settlement with the Justice Department for overseas bribery. He’s building up the company’s third-party oversight…
Read MoreSurvey, Good and Bad, on Compliance
LRN has published a new survey of ethics and compliance professionals that says employees are still fearful to report ethics violations, and that too many senior executives still aren’t promoting ethical behavior in their organizations. On the flip side, LRN also identified several characteristics of high-performance organizations that echo other industry surveys about training and…
Read MoreWhen Sanctions and Cybersecurity Collide
Compliance professionals talk constantly these days about cybersecurity, third-party risk, and sanctions compliance. Now we have an example from the news that is one headache-inducing brew of all three — and also, I fear, a harbinger of compliance and risk challenges to come. The company in question is Hikvision, a Chinese maker of security cameras.…
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