Archive for 2018

International Chamber of Commerce publishes conflict of interest guidelines

The International Chamber of Commerce – apparently the world’s largest business organization – recently published Guidelines on Conflicts of Interest in Enterprises. It is available for free download here. Among other things, the Guidelines provide a useful summary of what should generally be included in a COI compliance policy: Objective: […]

Conflict of interest? Who decides?

Many companies have, of course, escalation provisions for responding to allegations of wrongdoing. But do they need such provisions with respect to routine self disclosures of conflicts of interest? At least for some companies that allow line managers to approve disclosed conflicts the answer is, in my view, Yes. That […]

A short post on directors’ compliance duties

From the most recent issue of Compliance & Ethics Professional (p 3 of PDF). I hope you find it interesting.

Hire the guilt prone

In a recent edition of Knowledge at Wharton, Maurice Schweitzer of that school discusses a paper, “Who is Trustworthy? Predicting Trustworthy Intentions and Behavior,” he co-authored with T. Bradford Bitterly, a postdoctoral research fellow at the University of Michigan’s Ross School of Business, Taya R. Cohen, a professor at Carnegie […]

Compliance officers as entrepreneurs?

In a paper recently published by Boston University School of Law – The Law Office (LO) and Compliance Officer (CO): Status, Function, Liabilities, and Relationship  – Emerita Professor Tamar Frankel of that school quotes a former SEC official (John Walsh, then Chief Counsel, Office of Compliance Inspections and Examinations) as […]

I’ll be speaking on behavioral ethics with

Azish Filabi of  Ethical Systems at Navex’s Ethics & Compliance Virtual Conference on November 8. We hope you can join us.

New on the Compliance Program Assessment Blog

A post on confidentiality and C&E assessments. Rebecca Walker and I hope you find it useful.

New on the Compliance Program Assessment Blog

An excellent guest post by the always excellent Joe Murphy on certifications as a form of program evaluations.

Moot compliance court for corporate directors?

In their paper, “Short-Changing Compliance,”  John Armour (University of Oxford), Jeffrey N. Gordon (Columbia Law School), Geeyoung Min (Columbia Law School), argue: “Corporate compliance programs play a central role in society’s current response. Prosecutors give firms incentives—through discounts to penalties—to implement compliance programs guiding and monitoring employees’ behavior. However, focusing on the […]

Imagine the real

  An early post on this blog noted that among the more interesting phenomena of behavioral ethics was the impact that knowing or not knowing a party could have on how one treated that party. A set of circumstances that is relatively likely to lead to an ethical shortfall is where we do […]