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Ethics Internal Investigations Securities and Exchange Commission (SEC)

Thomas Fox - Compliance Evangelist

Internal Reporting and Investigative Lessons from Star Trek: The Conscience of the King

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

EY Fined $100 Million

In a stunning announcement, the SEC announced an enforcement action against the international auditing firm EY. The enforcement action could not have been more directly in the ethical wheelhouse, with significant compliance...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - March 28th, Phoenix, AZ

Looking for compliance training and networking in your area? SCCE’s Regional Compliance & Ethics Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

American Conference Institute (ACI)

[Virtual Event] 37th International Conference on the FCPA - December 2nd - 3rd, 9:00 am - 4:30 pm EST

The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more

Thomas Fox - Compliance Evangelist

From the Code of Conduct to Risk Assessment to Continuous Improvement

How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more

Thomas Fox - Compliance Evangelist

Why the Board of Directors Need an Investigation Protocol

Many companies have an investigation protocol in place when a potential compliance or other legal issue arises. However, many Boards of Directors do not have the same rigor when it comes to an investigation, which should be...more

Foley & Lardner LLP

Internal Investigations and Privileges: Two More Courts Rule

Foley & Lardner LLP on

Despite the global pandemic, the federal judiciary continues to issue rulings. In the last week, two courts provided guidance about when self-disclosures to the government waive the attorney-client privilege, underscoring the...more

Thomas Fox - Compliance Evangelist

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more

Thomas Fox - Compliance Evangelist

Farewell to The Hawk – Fair and Consistent Application of Discipline

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Thomas Fox - Compliance Evangelist

Hallmark 8-Confidential Reporting and Internal Investigations

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more

Thomas Fox - Compliance Evangelist

Senn Interview, Part III – Post Incident Remediation

I conclude my three-part series based upon my podcast interview of noted white-collar defense lawyer and Foreign Corrupt Practices Act (FCPA) practitioner Mara Senn, a partner at Arnold & Porter LLP. In Part I, I considered...more

NAVEX

Do Your Confidentiality and Employment Agreements Violate SEC Whistleblower Protection Rules?

NAVEX on

As the SEC takes aim at whistleblower “pretaliation” (attempts to muzzle whistleblowers via confidentiality and other employment agreements—overt or otherwise) ethics and compliance officers need to take practical steps to...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Thomas Fox - Compliance Evangelist

How Does Your Organization Treat Whistleblowers?

As almost everyone knows, Lance Armstrong spoke for the first time about his performance enhancing drug (PED) use recently on Oprah. On the first night he admitted for the first time that he used PEDs during his seven wins at...more

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