Starbucks and Policy Management Perils

Starbucks

Compliance officers live for policy and procedure most days. So as we study the regrettable incident of Starbucks and the Philadelphia police rousting two black men for sitting in one of the company’s coffee shops, compliance professionals should consider this point: at large organizations, a little bit of procedure can brew up lots of trouble.…

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Meanwhile, in the HR Dept…

salary history

Fascinating study from the Journal of Labor Economics that just came to my attention, examining how companies change their hiring practices once they stop asking job candidates about previous salary history. The conclusion: companies talk to more candidates, ask those candidates more questions, and offer them higher wages. The study was done by Moshe Barach…

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Quick Case of Kickbacks and COI

rankings

We have a fresh example of kickbacks and conflicts of interest gone awry, thanks to a nifty case from the Securities and Exchange Commission this week that busted a rogue stock trader nicknamed “the Phantom.” The Phantom’s real name is Brian Hirsch, 42. The SEC charged Hirsch and one of his customers, Joseph Spera, accusing…

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New Standards and ‘Shadow Process’ Risk

shadow process

In the cybersecurity world, executives worry constantly about “shadow IT”—the risk that employees will implement their own IT systems via the cloud without telling anyone, therefore exposing the company to unknown security risks. Here at The Exchange Community, as I listen to discussions of new accounting standards for revenue recognition and leasing, I see a…

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The Many Compliance Lessons From Utah Arrest

A story out of Salt Lake City this weekend was a powerful reminder of the perils of modern compliance training, policy management, and monitoring. Compliance officers may want to take note, because the tale of Alex Wubbels is bound to happen again somewhere else. Wubbels is a nurse in the burn unit of University of…

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United: Another Week, Another Lesson

Policy management

Apparently nobody at United Airlines read my post last week about the shifting balance of power in modern Corporate America: away from C-suites with a slavish devotion to policy, toward a public favoring common sense values and good judgment. The scandal last week was United exiling two girls for wearing leggings on a flight from…

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United’s Policy Management Lessons

Policy management

Compliance officers who want a glimpse of your future, look no further than the spectacle that unfolded Sunday morning at Denver International Airport: a tale of policy management mismanaged, reputation risk, and plenty of commentary on social media. Some day, some way, a headache like this will be yours. This time the lucky company was…

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Deeper Dive Into New DoJ Compliance Guidance

compliance guidance

Yesterday I did another “Compliance in the Weeds” podcast with Tom Fox, where our subject of conversation were the Justice Department’s new guidelines for evaluating corporate compliance programs. That guidance—46 questions that prosecutors might ask about your compliance program, across 11 broad categories—is manna from heaven for corporate compliance officers. The questions are specific. They…

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Refugee Ban: A Policy Management Disaster

Policy management

Corporations have every right, and often a duty, to push forward with new, unpopular policies. A significant part of any corporate compliance officer’s job is to help with exactly that unpleasant task. Still, what America witnessed this weekend with the Trump Administration’s refugee ban is among the worst policy management failures we’ve ever seen. Regardless…

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