Search Results for “harm”

The many harms from conflicts of interest

A new post in the FCPA Blog. I hope you find it  useful.

The harm from conflicts you often can’t see

A few days ago Newsweek ran a piece on the Trump family’s “endless conflicts of interest,” describing in detail several dozen actual, apparent and potential conflicts, and related ethical infirmities. Another such list is maintained and periodically updated by The Atlantic. The sheer volume of these cases is so overwhelming […]

Is corruption a harmless foul?

In a book review published last weekend in the Wall Street Journal titled “Two Cheers for Corruption,”  the prolific scholar Deidre McCloskey argues that while corruption can be harmful to some societies (such as Afghanistan, the subject of one of the books she reviews), “The Great Enrichment that America rode […]

Massive but (mostly) harmless conflicts of interest

The conflicts of interest will be enormous when  the recently announced merger between Publicis and Omnicom – each a giant ad agency (or collection of agencies) in its own right – is finalized.  Both companies, through their respective subsidiaries,  represent major players in such industries as automotive,   telecommunications,  food,  beverages, and beer […]

A pharma cure for moral hazard?

“Moral hazard” – one of the three  principal areas of focus of this blog  – refers to a situation in which there is a disconnect between, on the one hand, those with the capacity and motivation to engage in risky behavior and, on the other, those who will bear the likely […]

Combining Conflict of Interest Program and Risk Assessments

COI risk assessments and program assessments are two different things. But they can overlap to some degree and so it makes sense to consider how/how much they should fit under “one roof.” This is particularly so when both procedures are based principally on employee interviews, with some danger of duplication. […]

Compliance Officers as “ministers for the future”

In The Ministry for the Future   science fiction writer Kim Stanley Robinson draws a truly harrowing picture of the cataclysmic harm that climate change could inflict on our planet in the not-so-distant future. Might compliance and ethics (C&E) officers play a part in advocating for the future? His tale is also […]

More on reverse conflicts of interest

Consider the following (disguised) case, from some years ago… A company enters into a complex business arrangement where one of its managers has a relationship with the other entity.  The relationship is fully disclosed and approved pursuant to company policy on COI waivers.  After some  time, the arrangement runs into […]

Conflict of interest program assessments

Compliance program assessments come in all shapes and sizes.   For some – but not all – organizations it may make considerable sense to conduct a general program assessment.  For others targeted deep dive/program assessments may be more appropriate – particularly in the area of conflict of interest (“COI”). What does […]

Ethics Slobs: the opposite of “ethics champions”

In a recent post I noted that “the various investigations into President Trump and members of his administration and others have focused attention on an age-old debate whether careless wrongdoing is as reprehensible as is the intentional sort.” The answer is, I believe, yes. I further noted that “I do […]