Setting The Bar: Ensuring Integrity In Your Organization – Forbes Magazine

October 15, 2019

In today’s marketplace, a commitment to integrity is essential for every business. Not only does it ensure that employees will uphold organizational values and comply with the law, but when problems do occur, many regulatory and enforcement agencies offer credit if an organization demonstrates that it has an effective ethics and compliance program in place. As a business leader, you may think to yourself: “My organization has an ethics and compliance program, so we’re all […]

The perils of measuring compliance program ‘effectiveness’

October 8, 2019

A new report recently published by The Ethics and Compliance Initiative (ECI), the 2019 Global Business Ethics Survey, addresses the state of E&C programs across ten countries — USA, Brazil, UK, Spain, France, Italy, Germany, Russia, India, and China. Findings from the report are intriguing. They tell us something about the state of E&C practices in key countries, but they also show how difficult it is to measure program effectiveness. See the full post here.

How to Operate in the Boardroom with Integrity – Boardroom Bound Podcast with Pat Harned

August 21, 2019

After several years of depressing headlines on workplace ethics, it would be easy to give up on this subject. But Pat Harned, CEO of the Ethics and Compliance Initiative (ECI), thinks there is room for some (qualified) optimism. Though there is also a lot of work left to do! And Pat would know. She regularly advises senior leaders of global corporations on effective ways to build an ethical culture and promote integrity in organizational activities. […]

Effective Compliance Programs Look Beyond DOJ Guidance

July 31, 2019

Much ado has been made about the recent guidance on corporate ethics & compliance (E&C) programs issued by the U.S. Department of Justice (DoJ).  The attention is justified.  Starting with the Criminal Division’s Evaluation of Corporate Compliance Programs and continuing with the release of the Antitrust Division’s Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations, we now know more about the DoJ’s definition of “effectiveness” when it comes to E&C than ever before. Not […]

When your job is to teach corporations to do the right thing – CNN Business

June 26, 2019

Americans are concerned about some of the corporate practices that put people at risk: Mining and selling data in ways that compromise privacy. Using facial recognition software that leads to biased decisions. Sourcing materials from countries with few environmental or labor protections. That’s one reason why companies are putting more explicit emphasis on their ethical standards both publicly and internally. But how they formalize their commitment to ethics varies widely. There’s no hard data, but […]

FCPA Compliance Report – Episode 431, Pat Harned on ECI’s Impact 2019 Wrap Up

June 3, 2019

In this episode I visit with Pat Harned, CEO at the Ethics and Compliance Initiative. We discuss the ECI’s recently concluded annual conference, Impact 2019 and some of the highlights for both Pat and myself. The theme of the event was ECI’s High Quality Program (HQP) Framework Assessment. Some of the highlights from the podcast include: The key theme was the HQP Framework Assessment tool. How did the genius bar facilitate discussions around the tool? […]

FCPA Compliance Report-Bonus Episode — HQP and Framework Assessment

May 14, 2019

In special bonus episode, I present a full hour’s presentation of a panel discussion I recently chaired at the ECI Impact 2019 conference. The panel consisted of Steve Scarpino, Director, Ethics and Compliance at BP; Suzanne Mitchell, CCO at US Foods; and Karen Clapsaddle, Ethics Director Lockheed Martin. They were all involved in the design and creation of the ECI High Quality Program and had experience with the Framework Assessment. It was a great review […]

THE UPDATED EVALUATION OF CORPORATE COMPLIANCE PROGRAMS – GUIDANCE DOCUMENT: PART 3 – POLICIES AND PROCEDURES

May 6, 2019

It should be mandatory reading for every Chief Compliance Officer (CCO), compliance practitioner and professional or any other person interested in the latest thinking of the Department of Justice (DOJ) on what constitutes a best practices compliance program.

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 2 – A Well Designed Program

May 3, 2019

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference. It is an update to the 2017 Evaluation of Corporate Compliance Programs, released in February 2017. This new document is available for download at no charge. It should be mandatory reading for every Chief Compliance […]

Department of Justice Announces Sweeping New Guidance at ECI’s Annual Impact Conference

May 1, 2019

WASHINGTON, May 1, 2019 /PRNewswire/ — Assistant Attorney General for the Criminal Division, Brian Benczkowski, announced new guidance before an audience of leading ethics and compliance practitioners at the Ethics & Compliance Initiative’s (ECI) annual Impact conference. The AAG focused his presentation on the importance of an effective corporate compliance program and how such programs can influence prosecutorial outcomes. “We hope this updated version provides additional insight to both prosecutors and companies with respect to […]