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?

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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…

It’s Time to Question Everything About Best-Practice Compliance

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A strong company culture of integrity isn’t just a nice thing to have.

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.
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Managing Business Ethics

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Managing Business Ethics: Straight Talk About How To Do It Right by Linda K. Treviño and Katherine A. Nelson John Wiley & Sons, Inc., 5th ed. (2011) (public library) Summarized by David Newman Overview Treviño and Nelson present…
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Compliance & Ethics Programs

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  Hammurabi's Code, ca. 1772 BCE, included 282 laws, some of which often prescribed punishing noncompliance with the removal of one's hand. INTRODUCTION Compliance and ethics (“C&E”) programs are organizational policies…