Seven Signs of Ineffective Compliance Programs
Third party due diligence is a constant topic in corporate compliance. Almost always the process begins with input from the third party to provide information about itself: a questionnaire. Just how reliable is this foundational data? Problem with 3P DDQs
The posters, phone lines, and websites do not motivate people to report: people’s own sense of wrong, responsibility, and personal cost do. It’s the human factor where efforts need to be begin. For full post, click here.
In my interactions with the corporate compliance community, I have found a common lack of appreciation and vast under-utilization of data. When I speak with compliance education programs in both academic and professional settings, my questions on how they teach the use of data is most often met with blank stares. I believe this data … Continue reading Data Science is Here to Stay
Blog published via NAVEX Global's "You Can't Delegate Ethics" series. The Paul O'Neil at Alcoa story has always been one of my favorites to tell when it comes to senior level commitment.
In the 24 hours or so since the reporting of the U.S. President’s remark about immigrants, the reactions have been swift and strong. From the United Nations to leaders around around the world, the reported remarks have been rightly characterized as racist, degrading, reprehensible, among others. In such a time as this, silence is not … Continue reading Silence is not an option
One question I often get is my views on ISO 37001 (the “Anti-bribery management system – Requirements with guidance for use”, published October 15, 2016) and/or certification programs in general. An associated question is how does the Department of Justice (DoJ) view such certifications. On the second question, Dan Kahn, the Chief of the FCPA … Continue reading Toward Evidence-Based Programs: Thoughts on ISO 37001 and Certifications