All articles by Tom Fox – Page 13
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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.
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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.
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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.
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Is a country sweep coming to South Africa?
The recent corruption scandal to focus on McKinsey & Co., SAP, and KMPG in South Africa has driven home a truism that many in the compliance space have known for some time: South Africa is one of the most corrupt countries on earth. For U.S. and U.K. companies doing business ...
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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.
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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.
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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.
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Recovering from an ethical scandal
How does a company restore its reputation after an ethical failure? Tom Fox explores how KPMG will react after its faulty audits of the embattled Gupta family.
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Lessons from the Telia FCPA resolution
The largest FCPA resolution on record (so far), at nearly $1 billion, offers plenty of objective lessons for compliance practitioners looking to better understand enforcement trends.
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NACD report on board culture and corporate culture
Have boards of directors finally begun to wake up to their role in the fight against bribery, corruption and unethical corporate behavior? Tom Fox explores.
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The role of banks in corruption
A look at a recent report that examines allegations of bribery to purchase votes on the International Olympic Committee for the selection in 2009 of Rio de Janeiro to host the 2016 Olympics.
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Internal reporting: hotlines and listening
A look inside at some of the best practices for a hotline.
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Third-party lifecycle management
The Man From FCPA recommends five steps in the lifecycle of third-party management for the risk management process around third parties.
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Does the NCAA corruption scandal have an FCPA angle?
In a move reminiscent of FIFA arrests in 2015, the Department of Justice recently announced a series of arrests from an undercover operation exposing one of the sordid underbellies of college sports: the myth of amateurism at the highest level of collegiate sports.
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Corporate culture around whistleblowers
The unspoken reality in the corporate world is that many whistleblowers are deemed complainers, and yet, Congress, regulators, and even the companies that verbally demean whistleblowers recognize that those with personal knowledge of wrongdoing are often best placed to report it, writes The Man From the FCPA.
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Has Uber turned a page?
Uber may finally be changing its tune and, this time, in a very public way, writes The Man From the FCPA.
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How to use sticks in a compliance program
The application of discipline is a key aspect to any best-in-class compliance program, and yet many companies have never disciplined any employee for ethical violations, writes The Man From FCPA.
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Using incentives in a compliance program
As stated in the FCPA Guide, compliance programs need to have in place recognized incentives for doing business. The Man From the FCPA discusses what important parts an incentive program may include.
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Overcoming culture dissonance in compliance
A look at how chief compliance officers can operationalize compliance to make it relevant outside the corporate office in the United States.
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A promise to pay can be an FCPA violation
The South African imbroglio involving the Gupta family and their relationship to the current President of the country continues to be a sinkhole of reputational kryptonite. Tom Fox reports.