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 discuss many factors compliance teams should pay attention to when assessing culture, including:

  • Tone at the middle
  • How easy it is to speak up in the organization on all issues, not just compliance
  • Organizational justice
  • How conflicts of interest are managed
  • The industry’s culture
  • How customers are treated
  • Incentive plans
  • Rule following

Jeff Kaplan is a partner in the Kaplan & Walker LLP law firm in Princeton, New Jersey. He began his professional life in criminal defense but has spent most of the past 20 years practicing compliance-and-ethics (“C&E”) program law. He helps companies conduct C&E risk assessments, draft codes of conduct and other policies and procedures, develop C&E training and communications plans, and assess the efficacy of their overall C&E efforts.