Ethics & Culture

The manipulation of securities prices has been illegal under federal securities law for more than 70 years. Surprisingly, however, the Securities and Exchange Commission had never brought an enforcement action alleging market manipulation through the intentional spreading of false rumors until this past April. That’s when the SEC filed a settled case against Paul Berliner, […]

What is the best way to convince foreign nationals to agree to a corporate policy on complying with a U.S. law? In some cases, don’t mention the law. That’s one lesson Dana Nahlen, senior international counsel at EDS, has learned during her 26 years in the international compliance field. While a compliance policy can—and should—be […]

The following letter is in regard to the ethical dilemma of doing right vs. being right: Dr. Harned, I recently attended a conference on the Foreign Corrupt Practices Act, and heard the following ethical dilemma. A fellow compliance officer recounted how one of his company’s business-unit presidents, in a former Soviet Bloc nation, wanted to […]

I first heard the story on the radio: Merck, the pharmaceutical giant, had ghostwritten a number of research studies about a best-selling drug that, not coincidentally, Merck had developed. Prestigious doctors had then signed on as authors of the reports for publication in medical journals. An article in The New York Times condemned the situation, […]

There are a million reasons why companies should worry about who they do business with. Increasingly, an obscure law from the birth of the United States is one of them. The law is the Alien Tort Claims Act, passed in 1789 to let foreign citizens file actions in U.S. courts for violations of “international law.” […]

For years—essentially since the U.S. Sentencing Guidelines were first enacted in 1991—companies have been left pretty much to their own devices to figure out how to develop effective ethics and compliance programs that live up to (or go beyond) what the Sentencing Guidelines require. In their original incarnation (from 1991 to 2004), the compliance provisions […]

He was the sheriff of Wall Street, a rising star whom some believed might eventually occupy 1600 Pennsylvania Avenue. Beyond Wall Street, he wanted to change the ethics of New York State and perhaps the nation as a whole. But his own ethical decisions paved the way for his political demise and his disgraced exit […]

Aletter came to me from a reader not long ago, and I have to admit that her question gave me pause. (I’ve given the author a psuedonym.) Dear Pat, I read some of your articles in Compliance Week and wanted to seek your perspective on incentives—specifically, the thought of recognizing employees who have set an […]

With corporate scandals continuing unabated and hitting the headlines daily (the U.S. sub-prime mortgage crisis, Siemens’ bribery probe, Societe Generale’s rogue trader, to name a few), more and more organizations—whether corporate, non-profit, academic, or governmental—are adopting global codes of conduct for their employees, executives, agents, partners, and vendors. And these global codes are not necessarily […]

Rising numbers of mortgage defaults, growing business inventories, declining consumer confidence, falling interest rates, and roller-coaster trading sessions—without question, few economic indicators are heading in the right direction these days. Regardless of the terminology we will ultimately use to define this period in our economic development, it also doesn’t appear that the situation is going […]