JOIN ME: Webinar Revealing the Top Ten Biggest Mistakes Made by Compliance Officers

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JOIN ME: Webinar Revealing the Top Ten Biggest Mistakes Made by Compliance Officers

Join me on Tuesday, May 5th, as Tony Charles of Steele and I reveal the Top Ten Biggest Mistakes Made by Compliance Officers. In times of crisis, making mistakes can impact the business, your career, and the compliance program. Juggling multiple priorities in a constantly changing environment can be challenging.

In this fast-paced webinar, we’ll reveal the top ten mistakes compliance professionals make, and the actions to take to avoid them. As compliance professionals are grappling with an unprecedented environment of change, we'll be addressing many of your biggest challenges, including:

- The biggest mistakes compliance officers make in a crisis

- How to avoid alienating the business, and implement easy wins that can make a huge difference to the compliance program and your career

- How to influence management on the big picture while managing the crisis

In this difficult time, it’s more important than ever to do your best work to secure your position and the program. Join me to learn more about the top ten mistakes made, and how to avoid them to ensure you thrive! REGISTER HERE: https://hubs.ly/H0pXTSr0

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The New Top Ten Best Practices for the Code of Conduct

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The New Top Ten Best Practices for the Code of Conduct

A Code of Conduct is a foundational element of any compliance program. This document articulates a company’s mission, values, and guiding principles. It defines the standards of business conduct expected from the company’s leaders, managers, and employees. Moreover, the Code of Conduct serves as a reference guide for company personnel in exercising their day-to-day job responsibilities and making difficult decisions. Codes of Conduct are not new, but the trends in how you create (or revise) your Code of Conduct have been changing.

The importance of an effective Code of Conduct cannot be overstated. Regulatory agencies, as part of any investigation into misconduct, will scrutinize this document to gauge a company’s commitment to ethical business practices. Also, the Code of Conduct provides a unique opportunity for a company to promote a culture of compliance by clearly communicating what the organization values and believes in. Companies, therefore, are well-served in taking the time to carefully craft a Code of Conduct that inspires its personnel to further the mission of the company. Here are the top-10 new best practices for developing an effective Code of Conduct:

Number 1: Focus on Values and not the Law…

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The Art (and Necessity) of the Pivot

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The Art (and Necessity) of the Pivot

Right now, many people feel paralyzed and totally unmotivated. This is reasonable. As brain scientists explain in article after article, the news we consume and the uncertainty of this period freezes that higher-thinking parts of the brain, and we get stuck in cortisol-drenched fight-or-flight mode. It’s easy to reach for the familiar and to try to stay the course with our programs moving as they are now. But now isn’t the time for complacency. Now is the time for the pivot.

If you have a yoga, guitar, or other type of teacher, chances are that person has pivoted their business to provide online services. In response to the coronavirus crisis, most businesses have tried to find a way to have virtual or mail-driven service. For example, some hairdressers are sending packets of the color they use on their clients to keep an income and to keep their clients looking fabulous. A pivot is simply a turn or a change. Business as usual can’t go on the same way it has, for you or for the businesses in your neighborhood.

Questions to Ask

The first thing to do is to consider all of the new or expanded risks facing the business. Start with the following…

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Five Ways to Shift Perspective to Come out of this Crisis Better and Stronger

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Today I have decided to record my blog because I have so much to share – and much of it is significantly more personal than usual.  As is true of most of us at this time, I’ve struggled with fear of the unknown and sadness about what is happening.  I’ve searched for a perspective shift by listening to authors and thought leaders to help me find new ways of looking at the crisis, and their ideas have been tremendously helpful for me to find meaning, purpose, and new hope.  In this recording, I talk about both compliance and “real life,” and how to apply these perspective changes so that you come out of the crisis better and stronger.  Listen in to find out:

  • How to use the question, “How is this for me?”

  • Choosing how you want to remember this time

  • Using brain-based science to decide in advance how you’ll respond

  • How taking the smallest action can help overcome uncertainty

  • How to use touchstone words to keep you grounded  

I know that compliance will rise from this, because times like these create the seeds of prosecutions in one, two, and three years’ time as people cut corners, commit fraud, pay bribes, and act unethically out of fear and greed.  Now is the time to plan and to be vigilant.  Together we will come out of this better than ever.

The Very BEST Practices for Investigations

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The Very BEST Practices for Investigations

This is a guest post written by Elizabeth B. Hawkins, Esq., CCEP, Vice President & Assistant General Counsel of Targa Resources Corp.

There are many reasons that an internal investigation is required and by means in which they can become known to the company. Internal investigations should be conducted when there are allegations of minor errors in reporting or violations of company policies or procedures or allegations of misconduct in the workplace. The main goal of any internal investigation is to provide a sound, factual basis for the internal investigator to determine if there is a violation of the company’s code of conduct, relevant policies or violations of laws and make a recommendation to management as to whether an employment decision should be made. Consequently, the investigation should produce reliable documentation that can be used to support that employment decision.

This paper is not intended to address an investigation needed for a violation of state or federal law or regulations. These kinds of investigations should occur if there are allegations of misconduct that could result in criminal prosecution or civil litigation, the allegations had been publicized, or threats to report to a government agency.

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I. Understanding and Assessing the Report

Step 1: General Intake – the Report received

While many employee disputes, discrimination or harassment allegations, safety concerns or other employee misconduct are directed to the Human Resources Department, many such complaints come through the company’s ethics and compliance hotline. Regardless of how they are brought to light, an assessment must be made as to whether an internal investigation is needed.

Case management begins with the initial report and a well-defined process lends credibility to each investigation. Consequently, a focus must first be on the allegations. Are they reasonable? Do they make sense? Can they be adequately evaluated to determine if an investigation is necessary? Is there enough information to move forward? The first step in any internal investigation starts with establishing the credibility of the report. And, you cannot forget that, depending on your internal metrics protocol, the clock starts ticking when that report is made. More importantly, depending on the allegations, there may be a need for immediate action to stop serious misconduct which could harm people or property.

Step 2: Interview Reporter if possible

Depending on the report, there may be a need to clarify or obtain additional facts…

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