Search Results for “harm”

Training managers in conflicts of interest

While  COI risks can exist at any level of an organization, as a general matter the risks increase (often sharply) as one proceeds up the org chart.  Most obviously, this is because a) senior managers tend to have greater opportunities for COI-fraught relationships and activities than do other employees; and […]

A 30-year experiment in ethics and compliance

In his 2008 book Experiments in Ethics, Anthony Appiah made a strong and important case that behavioral science ideas and information should be used to address ethical challenges. But for me the most compelling ethics-related experiment of modern times comes from the realm of political – rather than behavioral – science: […]

Self assessing your conflict of interest compliance program

C&E program assessments sometimes have a general scope and sometimes are focused on a single substantive risk area – such as corruption or competition law. (Still others have elements of both approaches, i.e., general assessments and deep dives.) For some companies it makes sense to do such a targeted/deep dive […]

Should the fight against conflicts of interest be treated as a national priority?

President Biden recently received well-deserved attention for declaring the fight against foreign corruption to be a national security priority. Should conflicts of interest be viewed  in the same manner? In particular, how much does it matter that organizations, individuals and governments pay close attention to identifying and mitigating conflicts of […]

Caremark and caring about carelessness

Samuel Johnson once said: “It is more from carelessness about truth than from intentionally lying that there is so much falsehood in the world.” And carelessness is obviously at the root of many other types of wrongdoing too.  But what does this have to do with the liability of boards […]

Something new regarding gifts and entertainment

I once asked students in an executive MBA ethics class if they thought that their employer organizations should have restrictive policies on gift receiving.  Nearly all said that such policies were unnecessary – as the students were certain that they would not be corrupted by receipt of gifts from suppliers […]

Moral hazard and ethical habits of mind

“Moral hazard” means the provision of incentives that encourage unduly risky conduct by shifting the impact of a bad decision to a party other than the decision maker.   Perhaps the most consequential area of moral hazard ever is climate change, as those individuals most likely to bear the brunt of […]

Conflicts of interest: the role of norms

There has lately been much discussion of norms in the realm of politics and governance.  But norms are also important in the business world, particularly  those established within a profession. In Regulating Conflicts of Interest Through Public Disclosure: Evidence From a Physician Payments Sunshine Law, Matthew Chan of William College […]

Assessing your conflict of interest compliance program

Under Department of Justice standards for the government’s evaluating compliance & ethics (C&E) programs companies should undertake program self-assessments from time to time. What does this entail? At a minimum, it should include assessing the general components of the C&E program (e.g., compliance office, helpline, training) as well as corporate […]

Have you checked your behavioral externalities?

In The Case for Adding Darwin to Behavioral Economics posted on the Ethical Systems web site,  Robert H. Frank  of Cornell University’s Johnson Graduate School of Management writes: I use the term “behavioral externalities” to describe choices that affect social environments… Because social environments influence us so profoundly, both for good […]