Jkaplan


Behavioral ethics and compliance assessments

New from the Compliance Program Assessment Blog. Rebecca Walker and I hope you find it interesting.

Socialism and conflicts of interest

There was a time in my life when I might have embraced the cause of socialism, but that was many years ago and today I proudly march under the banner of centrism. And the current  flirtation with socialism in the US has me worried – at least a little bit. My […]

Conflict-of-interest policies and procedures

My latest column in C&E Professional (3rd page of PDF). I hope you find it useful.

Loyalty on the decline?

President Trump’s firing of then FBI director Jim Comey for refusing to pledge personal loyalty to him has given loyalty a bad name.  But on the whole loyalty plays an essential role in our business ethics/law framework. In The Diminishing Duty of Loyalty Professor Julian Velasco of Notre Dame Law […]

Deadly – and small – gifts and entertainment

Virtually every conflict of interest policy contains monetary limits for individual acts of gift giving or entertainment, but not all seek to quantify how many of such acts are permitted to occur in a given time period. This issue was raised in a particularly grim way – as described in this article […]

Behavioral ethics and compliance index 2019

While in the more than seven years of its existence the COI Blog  has been devoted primarily to examining conflicts of interest it has also run quite a few posts on what behavioral ethics might mean for corporate compliance and ethics programs. Below is an updated version of a topical  index […]

Compliance culture assessments – the why and the how

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

Inherent anti-conflicts of interest

A post some years back explored the idea of “inherent conflicts of interest,”  COIs so embedded in a situation that they are essentially impossible to resist. In an important column this week in Wired UK , the eminent behavioral ethicist Dan Ariely describes an approach he has developed which might […]

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 […]