Archive for 2015

A code of conduct for Caesar’s wife

“Follow the money” is as good a rule as any for an assessment of compliance risk, and this is surely true for conflicts of interest.   In many companies that trail leads to procurement – and often to the understanding that those involved in buying goods and services for a company […]

Conflict of interest TV?

Not exactly. But here is an audio recording with a video of PPTs of my presentation on Conflicts of Interest: Business, Law, Compliance and Social Science at the October SCCE Compliance and Ethics Institute. I hope you find it interesting.

“Point-of-risk” compliance

Marketers have long known that “point-of-sale” display of products can be a powerful advertising tool.  But can its logic be put to work for promoting compliance and ethics? I was recently asked by a client to fill out a vendor information form and noticed that in addition to seeking information […]

Ethical “have-nots”

The central notion of behavioral ethics is that We are not as ethical as we think and the central notion of compliance/ethics programs is that they can help fill the gap – at least for business organizations – left by our imperfect human nature.  But do C&E programs actually work? […]

Tending to personal matters on company time

Last week the Institute of Business Ethics published its 2015 Ethics at Work survey of employees in the UK and Western Europe, available for free download here.  One of the findings was that “employees tend to be more lenient towards conducting personal activities during work hours, than other practices.” For […]

Too big for ethical failure?

An article last month in a magazine published by the NY Times provided the occasion for a noteworthy COI discussion.  The Times had given Laura Arrillaga-Andreessen the assignment of profiling the head of Airbnb for an issue of “T” magazine. However, her husband, Marc Andreessen, is a substantial investor in […]

Making the most of managers’ C&E duties

Nearly every corporate code of conduct has a “managers’ C&E duties” section.  But most companies don’t do nearly enough to reinforce those duties in other parts of their C&E program (e.g., policies, training, other communications, auditing, investigations, discipline and personnel evaluations). In my latest column in Corporate Compliance Insights I offer […]

Compliance certifications and the law

Certifications play various roles in C&E programs (including but not limited to ensuring COI compliance).  But the legal efficacy of these sorts of documents varies widely based, in part, on the risks of certifying falsely – as discussed in my latest column in C&E Professional (page 2 of PDF.) I hope you […]

“Behavioral compliance”: the will and the way

“Behavioral ethics” information and ideas have, to date, been used far more to identify ethical challenges than to design approaches to address such challenges. In “Behavioral Ethics, Behavioral Compliance” (which can be downloaded for free here ) Professor Donald C. Langevoort of the Georgetown University Law Center takes up this […]

ECI forms benchmarking group for conflicts of interest

Yesterday the Ethics & Compliance Initiative (f/k/a the ECOA) announced the formation of four benchmarking groups to examine topics of significant interest to C&E practitioners. One of these is conflicts of interest, and I’ll be co-chairing that group with Mark Snyderman of Laureate Education. If you’re an ECI member I […]