Have boards of directors finally begun to wake up to their role in the fight against bribery, corruption and unethical corporate behavior? Name any of the most recent corporate scandals, Wells Fargo, Uber, Equifax, and one of the first questions asked was โWhere was the Board of Directors?โ From the FCPA perspective, consider the Telia Company FCPA enforcement action, the largest of all time, coming in with a total fine and penalty of $965 million and the same question can be posed.
In light of these and other recent corporate scandals, the National Association of Corporate Directors commissioned a blue-ribbon panel who issued a report entitled โCulture as a Corporate Assetโ. The report noted that โOversight of corporate culture should be among the top governance imperatives for every board.โ It goes on to relate that strong culture can be both a competitive business advantage and market differentiator.

