Archive for 2018

Assessing compliance training

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

Frequently asked questions about conflicts of interest

An earlier post  explored the various contexts – such as board meetings, hiring interviews, employee engagement surveys, training, compliance audits and exit interviews – where asking the right question can help promote C&E at a business organization. To this list should be added frequently added questions documents (“FAQs”). FAQs are […]

The spirit of liberty and the spirit of ethics

In the latest issue of National Defense magazine. Have a happy Fourth!

A new blog for compliance professionals

My law partner Rebecca Walker and I recently launched the Compliance Program Assessment Blog – a first-of-its-kind resource devoted entirely to the why and how of conducting C&E program assessments. We hope you find it useful. Thanks.

Building an ethical culture: where to begin

Increasingly, official and other important expectations regarding compliance & ethics (“C&E”) programs have a culture-related component. But where should C&E professionals start in addressing this important but challenging area? One very useful resource is Regulating For Ethical Culture, recently published in Behavioral Science & Policy,  by Linda K. Treviño of […]

Nonmonetary conflicts of interest

In “Using behavioral ethics to curb corruption” – recently published in Behavioral Science & Policy – Yuval Feldman of Bar-Ilan University notes  that “Classic studies on the corrupting power of money focus on politicians influenced by campaign donations and on physicians whose health care decisions are affected by the receipt of […]

A valuable behavioral ethics and compliance resource

The Institute of Business Ethics recently published Using Behavioural Ethics to improve your Ethics Programme, a Business Ethics Briefing. For those interested in “behavioral ethics and compliance” – a frequently addressed topic in this blog – the briefing is a must read. Among the suggestions made in this piece is: “Ethics needs to […]

The latest on compliance programs from the Department of Justice

For at least three decades the U.S. Department of Justice has been encouraging – including, in some cases, incenting – companies to develop and implement effective compliance programs, most recently in Deputy Attorney General Rod Rosenstein’s speech Monday at the annual Compliance Week conference in Washington DC. Every C&E professional […]

Does your conflict of interest risk assessment do this?

My latest column in Compliance & Ethics Professional, available on page 2 of attached PDF. I hope you find it useful.

Directors and compliance programs: a look at the law

Many years ago, I was previewing for a general counsel a presentation on compliance programs that  I was planning to make to his company’s board of directors, and I mentioned the real  prospect of individual liability under the Delaware Chancery Court’s 1996 opinion in the Caremark case.  (Caremark – for […]