Archive for 2018

Disclosure’s two-edged sword

Several prior posts reviewed the findings of various studies which raised questions about the efficacy of disclosure as a COI mitigant, including that: – Disclosure can “morally license” the conflicted party to act in a COI-based way. – Individuals impacted by the COI may not fully understand/be aware of what is […]

How to assess compliance investigations

The latest post by Rebecca Walker and me in the Compliance Program Assessment Blog. We hope you find it useful.

Conflict of interest risk assessment (part 2)

My latest column in Compliance & Ethics Professional. (Last page of PDF.) I hope you find it useful.

Loyalty and conflicts of interest

Movie mogul Samuel Goldwyn famously said  “I’ll take fifty percent efficiency to get one hundred percent loyalty.”  But too much loyalty may be bad for reasons that go beyond inefficiency, as indicated by President Trump’s call for then FRI director Comey to be loyal to him. In Ethics for Adversaries,  […]

Assessing compliance training

The latest post in the Compliance Program Assessment Blog. Rebecca Walker and I hope you find it useful.

Frequently asked questions about conflicts of interest

An earlier post  explored the various contexts – such as board meetings, hiring interviews, employee engagement surveys, training, compliance audits and exit interviews – where asking the right question can help promote C&E at a business organization. To this list should be added frequently added questions documents (“FAQs”). FAQs are […]

The spirit of liberty and the spirit of ethics

In the latest issue of National Defense magazine. Have a happy Fourth!

A new blog for compliance professionals

My law partner Rebecca Walker and I recently launched the Compliance Program Assessment Blog – a first-of-its-kind resource devoted entirely to the why and how of conducting C&E program assessments. We hope you find it useful. Thanks.

Building an ethical culture: where to begin

Increasingly, official and other important expectations regarding compliance & ethics (“C&E”) programs have a culture-related component. But where should C&E professionals start in addressing this important but challenging area? One very useful resource is Regulating For Ethical Culture, recently published in Behavioral Science & Policy,  by Linda K. Treviño of […]

Nonmonetary conflicts of interest

In “Using behavioral ethics to curb corruption” – recently published in Behavioral Science & Policy – Yuval Feldman of Bar-Ilan University notes  that “Classic studies on the corrupting power of money focus on politicians influenced by campaign donations and on physicians whose health care decisions are affected by the receipt of […]