There are some important lessons that can be garnered by CCOs when examining recent FCPA internal control violations made by Canadian gold and silver mining company Kinross.
Tom Fox
Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in compliance through his best-selling book Upping Your Game. He has 38 other books on the use of AI in compliance and business ethics, leadership including the seminal work, The Compliance Handbook, with its 7th edition coming out in 2025. He is the founder of the award-winning Compliance Podcast Network.
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Posted inAnti-Bribery
What does tone from the top really mean?
Is Novartis really answering to the recent allegations that have been brought against the company, or is the chairman just paying lip service?
Posted inInternal Controls
Post-mortem on Theranos—where were the controls?
Theranos’s fall from grace is one large-scale compliance failure. The reason? It’s all about internal controls, writes The Man From FCPA.
Posted inAnti-Bribery
Incorporating compliance into long-term strategy
How can a board work to incorporate the compliance function into a long-term business strategy of the organization? The Man From FCPA offers some suggestions.
Posted inAnti-Bribery
What is the price for profits?
LaFargeHolcim, a global construction materials and solutions company, is facing an investigation after it was uncovered that its Syrian operations funded terrorist groups to keep a cement plant operating.
Posted inAnti-Bribery
Of Saudi princes and gilded cages
If you have done business in Saudi Arabia or with wealthy Saudis over the past few years, now might be a very good time to review not only those business relationships, but also your FCPA compliance program, writes The Man From FCPA.
Posted inAnti-Bribery
March Madness and corruption
March Madness is looked at as one of the greatest sporting events of the year. It combines great play, underdogs felling giants, fantastic venues, devoted fans, and competition galore … but this year it offers something else: an abject lesson in the failure of ethical conduct of the very institutions engaging in March Madness.
Posted inBoards & Shareholders
Key factors to consider in any board-led investigation
Many companies have an investigation protocol in place when a potential Foreign Corrupt Practices Act or other legal issue arises. Many boards, however, do not have the same rigor when it comes to an investigation, which should be conducted or led by the board itself, writes The Man From the FCPA.
Posted inBoards & Shareholders
The role of boards is to ‘put sand in the shoes of management’
One of the ongoing questions from members of boards of directors is how to resolve the tension between oversight and managing. An excellent starting point to understanding this role is to consider the metaphor, “put sand in the shoes of management.”
Posted inBoards & Shareholders
CCO reporting to the board
Chief compliance officer reporting to the appropriate board of director’s compliance committee has to be structured carefully to promote ethics and compliance. Inside are five best practices that should guide the reporting.
