See inside for some tips based on the Justice Department’s Evaluation of Corporate Compliance Programs for help revising your Code of Conduct,
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 inUncategorized
Baseball informs your compliance program
With the Houston Astros set to play in the 2017 World Series, the Man From FCPA is tuning in and—much to his surprise—learning that baseball has multiple lessons for the compliance professional.
Posted inEthics & Culture
Culture, compliance, and the board
Companies need to beware of two debilitating types of corporate culture, according to Uber board member Arianna Huffington, “the cult of the top performer” and “the culture of burnout and stress.”
Posted inUncategorized
Harvey Weinstein—the FCPA angle
More trouble for Harvey Weinstein? The scandal-plagued Hollywood exec’s purchase of a $75K dress that was given to an un-named Qatari individual who was prepared to invest some $20,000,000 in an animation movie fund could be an FCPA violation.
Posted inAnti-Bribery
Post-acquisition integration under the FCPA
Companies should make sure they do three things in the M&A context, post-acquisition to ensure they don’t become entangled in an FCPA violation while attempting to expand.
Posted inAnti-Bribery
Pre-acquisition due diligence in mergers and acquisitions
This list of pre-aquisition due diligence tasks in the face of mergers will help companies thwart legal and business risks to reputation and profitability.
Posted inAnti-Bribery
What is your investigation protocol?
When viewing compliance as a clear series of steps leading to an effective goal, CCOs should take into account Hallmark 8 in the Ten Hallmarks of an Effective Compliance Program as supplemented by information from the Justice Department in its Evaluation of Corporate Compliance Programs.
Posted inAnti-Bribery
Continuous improvement through ongoing monitoring
Your compliance program should use ongoing monitoring to both evaluate and improve your regime going forward. And, writes Tom Fox, don’t forget to: document, document, document.
Posted inRisk Management
What is high risk for your brand?
The fraudulent certification scandal that rocked Japanese steel manufacturer Kobe Steel serves as a warning to other companies: Make sure your front-line employees feel like they can speak up in the face of fraudulent behavior.
Posted inEurope
Germans arrest VW executive
Will the recent arrest of VW former Chief Engineer Wolfgang Harz mean more prosecutions of those involved in the worldwide cover-up of the emissions testing scandal? Tom Fox has more.
