Are you ready for Compliance and Ethics Week?
This year Compliance and Ethics Week is scheduled for November 7 – 13 2021.
For the second year running, many activities will need to be done virtually. That creates tremendous challenges. After all, it’s difficult to do “cupcakes with compliance” if no one is in the office to share them.
Here are 14 ideas, all of which can be done virtually - enjoy!
Read MoreJust when you think you’ve got all the best practices in place, another comes raging to the forefront. And that’s exactly what’s happening today with Codes of Conduct.
It used to be that board members would be asked to attest to the company’s Code of Conduct. That seems fine at first until you think about all the sections of the Code that simply do not apply because a board member isn’t an employee.
For instance, does the section on resale price maintenance really apply? How about the requirement to begin a privacy impact assessment before starting new uses of data? Hence the reason for a board-specific Code.
Sound hard to create? It’s not. Read more for the step-by-step process.
Read MoreLet’s think back to your last major blunder.
You probably agonized over it, right?
You kept going over and over what you did wrong and how you could avoid doing that again in the future.
Sound familiar?
But what about those times you got it completely right?
Let’s have a think about them…
Read MoreThe hottest three letters in the corporate world are “ESG.”
Environmental.
Social.
Governance.
As compliance vendors fall all over themselves setting up workshops and webinars to explain what each letter means, there is very little information about who should take on this new blended responsibility in companies.
Since few companies are hiring new people to run ESG, the question becomes which person or department should oversee it?
The answer is compliance. But, why? Well because…
Read MoreIt’s nearly midnight. The lawyers, accountants and top management have been working away in secret for months.
The deal is about to be announced – a huge strategic acquisition that will bring the company great benefits and rock the market.
You get a call at 11:59p.m.
The CEO quickly asks, “do we need to do some kind of compliance due diligence before we announce the deal in six hours?”
Or worse, you don’t get the call at all. You find out along with all of the other employees at the all-hands meeting.
Considering the specter of successor liability for bribery and other compliance-related misconduct, compliance should be the first department called once a merger or acquisition begins to be seriously discussed. But even if we have the luxury of being called, we don’t always know what to do to perform proper due diligence on the target company. Here’s where to start…
Read MoreThe auditor enters the building, clipboard in hand. They run through the checklist: quality, pace, speed, and financial records. They give a score, make notes on remediation and opportunities for improvement, then leave. They never see that the workers are on their seventh straight 14-hour shift without adequate breaks. They don’t ask to see the living quarters. Why? They weren’t told to look.
Modern Slavery has become an increasingly focused-on area of compliance, and for good reason. It generates $150 billion a year in illegal profits making it the third-largest criminal industry behind drugs and arms trafficking. The International Labor Organization estimates that there are 40.3 million victims of human trafficking globally. One in four victims are children, and more than 16 million people are exploited in the private sector throughout a wide range of industries.
While governments around the world are beginning to address this issue with increased urgency, commercial enterprises can play a significant role in combating this evil. How do you ensure your company’s business activities are not indirectly supporting, encouraging, or financing Modern Slavery? One of the most effective and easily implemented measures your company should adopt is…
Read MoreIn most business relationships, there is some balance of power. But when it comes to third-parties, your company holds all the cards. Most third-parties will go through all the hoops required to get the contract. Compliance’s response to that is often to create gold-plated third-party risk management programs that go so far over the edge that they actually add risk to the company. How?
Let’s say there’s a company with a tiny compliance department that is tasked with managing the third-party program. The scope is “all third-parties,” and it is impossible to review everything that comes in.
Imagine You’re a Prosecutor…
Now imagine for a moment that you’re a prosecutor who just initiated a bribery-related investigation at that company. You pull up the due diligence report on the guilty third-party and bingo – in several adverse media reports, there are references to prior misconduct. The company had the information, but no one reviewed it because they had far too many records to review. How would you, as a prosecutor, feel about that failure?
If you ask for too much information and documentation, you won’t be able to focus on the key pieces that really drive risk. 20+ page due diligence questionnaires, requests for references, licenses, business intake forms, and multiple background checks may make it impossible to do the job properly. This is especially true if you haven’t taken a risk-based approach, so you ask for in-depth information from all third-parties instead of the ones that really present risk.
What are you Going to Do with It?
When evaluating requests for information, ask yourself this question: what am I going to do with it? For example, many third-party due diligence questionnaires ask for banking references and business references. Answer truthfully -…
Read MoreDo you know a leader who has driven strategic risk management programs at their organization? Nominate them today for the Diligent Modern Governance 100 Risk & Compliance Visionary category. I’m a judge for this category, and I'm excited to learn about the outstanding nominees! CLICK HERE TO NOMINATE YOURSELF OR SOMEONE ELSE!
Read MoreThe idea that “absence makes the heart grow fonder” is so 2019. According to US News & World Report, 44% of workers prefer working from home. In 2021 and beyond, some of us may work from home indefinitely – whether by choice or design. Others of us are bounding back to the office. From this, an emerging new complexity has emerged called “proximity bias.” Proximity bias is defined as “a cognitive bias where we value what’s close to us in time and space.”
Proximity bias is problematic in two ways. First, it can be used against us if we’re not careful, and second, we can deploy it without being conscious of it. Here’s how to deal with both of those challenges.
Protect Your Career
If you’re going to be working from home either part-time or full-time, be aware of the tendency of your boss and others to favor those working physically near to them. Create strategies to be visible and top-of-mind. These can include:
Scheduling a regular Zoom face-to-face each week or two weeks with your most important stakeholders.
Speaking up at least one time in each meeting in which you participate.
Requesting plum projects and positioning yourself for promotability.
Forwarding emails to your boss or stakeholder group when someone praises your work.
Taking credit for innovations or ideas that you came up with.
Ensuring your contributions are noted in group projects.
By making conscious efforts to protect your career, you’re more likely be successful.
Protect Your Team…
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