A Behavioral Ethics and Compliance Primer

In 1991, when the Federal Sentencing Guidelines for Organizations went into effect, Compliance and Ethics (“C&E”) programs became a part of the business landscape in the United States. There was, at the time, a fairly widespread…

Why Promotion Is a Moral Hazard

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"When leaders very publicly fail due to ethical lapses, some people are inclined to say, 'See, that’s just how business is,' instead of learning a more inspiring lesson." Jessica Kennedy gets frustrated when people—often academics—try…

Do Compliance Professionals Have a Maginot Line Problem?

One of the most powerful episodes in risk-assessment history is the story of the Maginot Line, which the French military had deployed after WWI to prevail in any future trench warfare against the Germans. The latter, however, had other…

Our List of Resources for Designing Compliance Programs with Behavioral Science

Last December, a friend of Ethical Systems—a Chief Compliance Officer at a major multinational consumer products company, whose expertise is second to none—sent us an email. He was curious to know how concepts from behavioral science…

How to Assess Corporate Culture: A Conversation with Jeff Kaplan

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In this episode of the Compliance Perspectives podcast, host Adam Turteltaub speaks with Ethical Systems Steering Committee member Jeff Kaplan about how corporate culture can influence the effectiveness of a compliance program. They…

Do Compliance Officers Have an Inherent Conflict of Interest?

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Should compliance be subordinated to legal, rather than separated from it? Yes, argues Sean J. Griffith, of the Fordham University School of Law, in a recent paper, titled "Agency, Authority, and Compliance." This is an interesting and…

4 Pillars of Business Integrity from the World Economic Forum

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This time last year, I traveled to Dubai to participate in the Global Future Council on Transparency and Anti-Corruption. The World Economic Forum’s Global Future Councils are an interdisciplinary multi-stakeholder network, grouped into…

Is a Weak Compliance Program Worse Than No Program?

Many years ago I was asked by a prospective client if I could design a “C minus” (i.e., just barely passing) compliance program for them. I responded that, for various reasons, by aiming for a C minus they were likely to end up with…

Why It’s Important to Know Who the Victims of Corruption Are

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One of the more complex and instructive business scandals of the 1980s concerned fraud in the sale of specialty pipe.