Archive for 2014

Risk assessments for office romances

Perhaps the most celebrated story ever about a love affair is Anna Karenina  and the story doesn’t end well – as the distraught heroine throws herself under a train.  Office romances typically don’t end that way, but they are not without risks – particularly those involving senior leaders. This is […]

Business ethics research of interest to your whole company

In this article from the most recent issue of Ethisphere magazine Jon Haidt of NYU and I take readers on a tour of the Ethical Systems web site. “EthSys” offers  cutting edge social science research that should be of  interest not only to C&E professionals but also  to board members and executives; to those working […]

With a little help from my friends – the why and the how of C&E program liaisons

In large and widely dispersed organizations, compliance and ethics program liaisons often play an essential role in ensuring program efficacy. Among other things, they can help extend the reach of the program  – both geographically and deeper into the business. Their knowledge of local culture, law and business personnel and […]

The cost of director and officer conflicts of interest just went up

In the vast realm of conflicts of interest those involving boards of directors tend to stand out. That is because part of the reason the role of corporate director even exists is to mitigate the conflict-of-interest-type tensions (which fall under the broad heading of “agency problems”) that managements may have […]

Operational transparency and internal selling of C&E programs

While all companies try to “sell” their  C&E programs, often such efforts are  not particularly robust. And that’s too bad, because the need for effective C&E program selling measures is considerable.  This is due in part to the behavioral ethics/psychology-related phenomenon that we tend to overestimate how ethical we are, […]

Is Wall Street a bad ethical neighborhood?

For many years I taught ethics in the executive MBA program of a New York area business school. Because of the school’s location, the “day job” for many of the students was in the financial services field, and on average they seemed less ethics-focused than did the others.  I did […]

Conflicts of interest, corruption and fraud: what are the connections?

Whether one is drafting a code of conduct or other C&E policy documents, developing training, designing audit protocols,  conducting a risk or program assessment or creating C&E metrics, it may be useful to bear in mind the relationships between COIs, corruption and fraud – particularly given the extent of overlap […]

Risk assessment: law, economics, morality science…and liquor

Many years ago a client who was in the compliance department of a pharma company told me his strategy for conducting risk assessments.  He would schedule the interviews of sales people – a key, but typically difficult, constituency for nearly any risk assessment – to begin late in the work […]

Internal auditors as compliance program helpers: opportunities and independence challenges

Internal auditors often have the skill set and opportunities to lend an important hand to their respective companies’ C&E programs beyond the program-related audits that they conduct.  But such assistance can raise independence issues where the activity in question itself  should be audited.  This post considers what some of these […]

The modern era of compliance and ethics at ten years old

This week will see the tenth anniversary of the advent of the revised Federal Sentencing Guidelines for Organizations – the most influential set of official C&E-program-related expectations ever issued. More than any other legal development,  these revisions – which went into effect on November 1, 2004 – made possible the […]