Archive for 2015

C&E program assessments – a “teachers’ guide”

This week I chaired the PLI Advanced Compliance & Ethics Workshop – and presented on program assessments. The PPTs for this presentation can be found here. The first part provides an overview of assessments (methodology and scope) and the second a high-level description of assessment criteria. I hope you find it […]

Conflicts of interest presentation from SCCE conference

On Monday I spoke on COIs at the SCCE’s annual Compliance and Ethics Institute. The presentation materials can be found here. I hope you find them useful.

Glory as a conflict of interest?

An editorial last week in JAMA – the Journal of the Medical Association  by Anne R. Cappola, and Garret A. FitzGerald about conflicts of interest in medical research notes that “disclosure policies have focused on financial gain. However, in academia, the prospect of fame may be even more seductive than fortune. […]

Curbing compliance waste

Legendary merchant John Wanamaker once said: “Half the money I spend on advertising is wasted; the trouble is I don’t know which half.”  C&E officers frequently have a similar feeling. It will often seem hard to know what parts of a training program are truly necessary, and the same can […]

Compliance program assessments: legal mandates and moral hazard

In my most recent column in Compliance and Ethics Professional I look at legal mandates for conducting C&E program assessments – and how assessments can help mitigate dangers posed by the phenomenon of moral hazard. I hope you find it interesting.

Come to the PLI Advanced C&E Workshop

Rebecca Walker and I are chairing the Advanced Compliance & Ethics Workshop again – this year in NYC on 10/13-14 and in SF (and on the Web) on 11/19-20. Lots of great speakers. Here’s the agenda. Hope you can make it.

Board conflicts of interest in an age of behavioral ethics

Rebecca Walker and I write about  directors and COIs in the latest issue of Corporate Board magazine.  Along with a discussion of behavioral ethics,  we include a list of topics that COI policies should address. We hope you find it useful.

How ethically confident should we be?

My favorite Marxist philosopher – Groucho – once said: “I have nothing but confidence in you, and very little of that.” But the same is not true of how much confidence we tend to have in ourselves. An article last week in the Slovak Spectator  reported that “one of the […]

A dream remit for the new DOJ compliance counsel

The biggest C&E-related news of the summer to date is the story last week (as reported here by NPR) that “Justice Department lawyers who prosecute errant corporations and executives are bringing in a new member to the team — a full-time expert in compliance programs. Andrew Weissmann, who leads the […]

Are conflicts of interest policies a violation of labor law?

In recent years, an unfortunate – in my view – line of decisions and reports has been issued by the U.S. National Labor Relations Board (“the NLRB”) holding that various aspects of company policies violate the National Labor Relations Act (“the Act”).  For those looking to learn more about this […]