Over more than three decades of defending claims, litigating False Claims Act cases, and helping clients avoid suspensions and debarments, my law firm colleagues and I have learned a fair amount about risk and what makes corporate compliance programs succeed or fail.
ethics and compliance program
Tone in the middle: Why compliance programs succeed or fail with managers
Global compliance programs often feature codes of conduct, policies, training, hotlines, investigations, and risk assessments. While these “seven elements” are essential, they do not guarantee an effective E&C Program.
The fastest way to scale integrity? Embed it in culture through values.
Ethics and compliance are often perceived as a form of protection for an organization. That framing is just one part of the picture.
HQP Assessment: Top Strengths and Weaknesses of Ethics and Compliance Programs
Most companies have in place the foundational elements of an ethics and compliance program, but the more elusive elements that get to the heart of improving corporate culture provide key opportunities for improvement, according to the latest findings of the Ethics and Compliance Initiative’s High-Quality Program Assessment.


