Archive for 2016

Conflict of Interest at Harvard and the Need for Deterrence

We are pleased to have this guest post from Jameson W. Doig, Visiting Research Professor of Government, Dartmouth College  and Professor Emeritus at the Woodrow Wilson School of Public and International Affairs. On September 12, the Journal of the American Medical Association carried an important story regarding conflict-of-interest in research […]

Would a Trump presidency spell the end of ethics and compliance?

Many years ago, I helped provide E&C training to a group of Russians visiting the U.S. The apparent hope of the session sponsor (the Commerce Department) was that these individuals would use our information to implement programs in Russian companies. The visitors seemed interested in the presentations but at one […]

The Wells Fargo Bank case and behavioral ethics

In 1170 King Henry II of England, unhappy with Archbishop Thomas Becket, asked of his knights: “Will no one rid me of the meddlesome priest?” Taking his words (the specifics of which have been the subject of historical dispute) as royal instruction, several of those knights assassinated the clergyman. Correctly or not, […]

“Tailoring” the duty of loyalty

A prior post provided an overview of “corporate opportunities” – an important and somewhat distinct type of COI. Last week, writing in the Harvard Corporate Governance Blog, Gabriel Rauterberg of Michigan Law School and Eric Talley of Columbia Law School described some fascinating research they conducted regarding companies allowing their […]

Behavioral compliance: back to school edition

In the waning days of summer, here is a roundup of some recent  notable writings about using behavioral ethics to enhance corporate compliance efforts. First is a post on the Compliance and Enforcement web site by Timothy Lindon, the Chief Compliance Officer of Philip Morris International. In it, he suggests […]

CEOs’ ethics: what’s new

In the past week, three stories relating to CEOs caught my attention. The first was a recent report by the research organization MSCI on CEO compensation, the summary of which provides: Has CEO pay reflected long-term stock performance? In a word, “no.” Companies that awarded their Chief Executive Officers higher […]

Should there be an “Open Payments” Database for Healthcare Executives?

By Bill Sacks [We are very pleased to have this guest post from Bill Sacks, Vice President, COI Management at HCCS.  He can be reached  at] Many individuals personally involved in the healthcare industry are familiar with the “Open Payments” database published each year by the Center for Medicare […]

If Trump becomes President

In the fourth volume of his biography of Lyndon Johnson  Robert Caro describes how, once in office, the President put his extensive personal business interests into a blind trust… but also took steps to manage those interests on the sly, including having “a private line installed in the White House so […]

Specialty bias

A recurring theme in Doonesbury during the presidency of George W. Bush was that whatever the challenge he was faced with the President would respond by cutting taxes for the wealthy. The reason was not nefarious, according to the comic strip. Cutting taxes was simply what he knew best how […]

Compliance officer pay: the government speaks

In my latest column in Compliance & Ethics Professional (page 2 of this PDF) I discuss recently articulated governmental expectations regarding  C&E officer pay – and the related issue of how “tough” C&E officers need to be. I hope you find it useful.