Archive for 2013

Catching up on backdating

Many years ago, I heard a businessman who had been convicted of tax fraud describe how he and his confederates had, while their crime was underway, minimized the wrongfulness of what they were doing, which included backdating documents: we used to joke, he said, that we were so dedicated that […]

Know thy culture

Here,  on ECOA Connects, is part three of my conversation with Steve Priest on ethical organizational cultures – with the focus of this latest piece on methods for assessing culture. We hope you find it interesting.

Moral intuitionism and ethics training

In their recent article in the Journal of Management – Moral Intuition: Connecting Current Knowledge to Future Organizational Research and Practice –    Gary R. Weaver of the University of Delaware, Scott J. Reynolds of the University of Washington  and Michael E. Brown of the Pennsylvania State University  review “a rapidly […]

Conflicts of interest and constitutional rights

Can a conflict of interest be protected by a constitutional right?  The answer is Yes.  Campaign finance – at least in the US – is a prominent (some would say glaring) example of this. But what about in the more common context of employment?  Again speaking specifically of the US, […]

An important real-world conflict of interest experiment

In today’s NY Times, Michael Greenstone, an economics professor at MIT, writes about a study on auditor COIs that he –  together with Esther Duflo of M.I.T.;  and Rohini Pande  and Nicholas Ryan, both of Harvard – recently published.   The study was conducted in Gujarat, India, where industrial plants with […]

Mitigating holiday cheer: what’s new in gifts and entertainment compliance

It is that time of year again, and so we look once more at what’s new under the C&E officer’s tree to help with the timeless challenge of gifts and entertainment (G&E)  compliance. First, in what seems like just yesterday (because  it was just yesterday), “[a]n employee of Deutsche Bank‘s […]

Characteristics of ethical organizational cultures

My latest conversation with Steve Priest in ECOA Connects – on what makes an organizational ethical or unethical – is available here.  This is the second installment in a multi-part series on ethics and corporate culture, and includes what may be the best single question one can ask about any given […]

When blowing the whistle is a conflict of interest

Employees generally owe duties of loyalty to their companies (at least under US law), but for some time whistleblowing has not seen as a breach of such duty.   This was the underpinning of an important Supreme Court case thirty years ago – Dirks v SEC  – which held that an […]

Thanksgiving edition: conflicts of interest and cholesterol

For millions of individuals (including me) Thanksgiving is not only a time for giving thanks but also for thinking about cholesterol.  And  if guidelines recently issued by the American Heart Association and American College of Cardiology are followed, the number of us who use  statins – cholesterol reducing drugs – […]

Three lines of defense – and two C&E “fronts”

The many forms of C&E “checking” – auditing, monitoring and self assessment – grow increasingly important as programs grow in size, scope and complexity. In my latest risk assessment column for Corporate Compliance Insights I explore this always challenging area of C&E program practice and offer several strategies for getting […]