I got scolded by the SEC’s John White once. Seriously: I got a verbal slapdown from a regulator—and I think I deserved it. The incident occurred in May of this year. White, who is the director of the Division of Corporation Finance at the Securities and Exchange Commission, had agreed to deliver the opening keynote […]
Ethics & Culture
The Role of Gifting in Corporate Social Responsibility
Many large (and not-so-large) companies have embraced a measure of responsibility for social needs, based in part on the premise that the corporation owes its existence to the state, or society, and consequently should be a good citizen. Few would argue with this. The term “corporate social responsibility” typically begins with a focus on such […]
Backdating Conviction Sets Unsettling Tone
The first criminal conviction of a corporate executive over backdated stock options has Corporate America buzzing about what the government’s victory bodes for the many, many other companies embroiled in the backdating mess. Earlier this month, a California jury convicted Gregory Reyes, former chief executive of Brocade Communications Systems, on 10 counts of conspiracy, securities […]
Being Legal, Honest, And Candid And …
As a Compliance Week reader, you know well the difference between taking an action that’s legal and one that’s ethical. “Legal,” of course, includes acting according to written laws and related regulations, as well as what is deemed legally correct by the judicial system. Acting ethically involves going beyond what is legal, focusing on principles […]
IRS Pushing Expansion Of FIN 48-like Reporting
The Internal Revenue Service is pushing a dramatic expansion of how tax returns must report the certainty of the tax positions they claim, imposing new burdens on tax preparers and essentially forcing the already unpopular rule for financial statements onto the corporate tax return. The change in tax compliance is part of a provision in […]
Ethics Online: What A Good Internet Policy Looks Like
OK, compliance and ethics directors: what would you do if your e-mail monitoring system uncovered a romantic relationship between two employees?Or what would you do if you discovered an employee was using his office computer to post corporate information—though completely banal—on his personal blog? E-mail and Internet usage—not to mention newer technologies such as blogs […]
How To Measure Ethical Culture
It’s the $64 million question in Corporate America: How do you “measure” culture and determine whether your ethics and compliance initiatives really work? Despite the mainstreaming of governance and compliance, that challenge remains daunting for companies of all stages and sizes, according to a panel of compliance experts. Klafter “We’re still struggling to figure out […]
Enforcing An Ethical Line Against Bribery
In February 2007, health products giant Johnson & Johnson disclosed that some of its foreign units might have made improper payments related to the sale of medical devices. By voluntarily disclosing the information to the Justice Department and the Securities and Exchange Commission, pledging full cooperation with the agency investigations, and accepting the early retirement […]
Building A Compliance And Ethics Function
Having established global compliance and ethics functions and implemented programs at two multinational companies with a combined total workforce of more than 150,000, and having networked with hundreds of my peers in other companies, I’m often asked what I would have done differently in my jobs or to summarize my most valuable lessons learned. Aside […]
Keeping Your Ethical Resolutions In 2007
Walk into any fitness club this time of year and witness the phenomenon: What started on Jan. 1 as an unwavering commitment to get in shape has become a struggle to keep the momentum, if not an outright surrender. Gyms that were packed with people three weeks ago are starting to look deserted. For many […]


