Archive for 2013

Come to the Advanced C&E Workshop

On October 24 and 25 – together with David Wilkins of The Dow Chemical Company – I’m chairing the Practising Law Institute’s Advanced Compliance and Ethics Workshop in NYC.  We’ll be covering all major aspects of C&E programs and will be joined by an all-star team of presenters. The full agenda […]

What counts as a conflict of interest policy?

Conflict of interest policies were in the news last week.   The first story comes from the world of medical schools. As described in a recent issue of Science Codex, “U.S. medical schools have made significant progress to strengthen their management of clinical conflicts of interest (CCOI), but a new study demonstrates […]

“Parental controls” – compliance programs for joint ventures and subsidiaries

Plumbing is often seen as boring.  But when something goes wrong with it, everyone appreciates just how important plumbing is. In a business organization, much of the C&E “plumbing” consists of governance measures.  This, too, generally seems like an uninteresting topic.  But for complex organizations – and particularly those with many […]

Behavioral ethics and C-suite behavior

As the COI Blog has discussed previously, CEOs often have different conflicts of interest from  you and me.   More generally we have seen from behavioral research that those with power may be at greater risk of engaging in unethical behavior than are others.  In “’C’ Is for Crucible: Behavioral Ethics, Culture, […]

The problem with apparent conflicts of interest

Virtually all codes of conduct prohibit apparent, as well as actual, conflicts of interest.   Apparent COIs are generally seen as less serious than actual ones.   Moreover, many compliance officers and others who conduct internal investigations are familiar with situations where it is hard to prove an actual COI (even where it seems obvious […]

Professionalism and conflicts of interest

Last Friday, Dylan Byers’ Media Blog in Politico announced a new Conflict of Interest Series, noting:  “Almost everywhere you look there’s someone in the media who’s ever more connected with the subjects they cover.”  The Media Blog has indeed covered a number of potential COIs in this industry, including, most […]

Risk assessment, program assessment and conflicts of interest

In my most recent column for Corporate Compliance Insights , I explore points of intersection between C&E risk assessment and C&E program assessment – two important functions that, while conceptually distinct, overlap to a considerable degree with each other.  In today’s posting I’d like to continue that discussion insofar as the […]

“Is this a hill worth dying on?”

Few, if any, other jobs run the risk that E&C officer positions do that doing the right thing can lead to loss of employment (and maybe career suicide). In this latest conversation on ECOA Connects  Steve Priest and I look at the timeless issue: Under what type of circumstances involving management wrongdoing should an […]

Dangerously narrow views of public – and self – interest

Last week the Financial Reporting Council (FRC), the  body that regulates the accounting  profession in the UK, fined Deloitte L.L.P.  £14 million pounds – a record setting penalty for that body – and issued the firm a severe reprimand, as well as fining  a former director of the firm £250,000 and […]

Using behavioral ethics means to reduce legal ethics risks

In various prior posts the COI Blog has explored the potential impact of “behavioral ethics” on how compliance and ethics programs are designed and deployed, and separately has asked whether law firms should have C&E programs to address legal-practice-related risks.  So, I was delighted to learn recently of a soon-to-be-published paper which more or […]