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Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

The Volkov Law Group

LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II)

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LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more

Thomas Fox - Compliance Evangelist

Transforming Culture: Part 5 – Ongoing Monitoring and Continuous Improvement of Culture

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other...more

Thomas Fox - Compliance Evangelist

Transforming Culture: Part 2 – The Role of Leadership

Boeing is not the first company to find itself amid a massive scandal. You can think of Siemens’ bribery and corruption scandal, the VW emissions-testing scandal, the Wells Fargo fraudulent accounts scandal, or any other...more

Thomas Fox - Compliance Evangelist

Role of Leadership in Culture and Course Correcting

When it comes to leadership, many people focus on qualities like decisiveness, communication skills, and strategic thinking. While these traits are undoubtedly important, there is another aspect of leadership that often gets...more

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

The Volkov Law Group

ECI’s New Survey – The State of Ethics & Compliance in the Workplace

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The Ethics and Compliance Initiative (“ECI”) is a terrific organization that provides important ethics and compliance insights and leadership.  Starting in 1994, ECI has conducted a longitudinal, cross-section study of...more

NAVEX

NAVEX R&C Benchmark Finding: Programs Still Have Opportunities to Better Utilize Data

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NAVEX publishes the Definitive Risk and Compliance Benchmark Report each year, surveying over 1,100 industry professionals. The purpose of this report is to provide insight into the effectiveness of R&C programs and enable...more

The Volkov Law Group

Insights from Recent NAVEX Global and KPMG Surveys

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Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry.  Compliance...more

The Volkov Law Group

The State of Corporate Board Performance and Accountability (Part I of IV)

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It is perhaps fitting that we are coming up on the one-year anniversary of the Business Roundtable’s Restatement of Corporate Purposes, which was signed by 181 corporate leaders and widely-praised for its expansion of...more

Latham & Watkins LLP

Wachsende Bedeutung der Unternehmenskultur

Latham & Watkins LLP on

Was Unternehmen aus einem der größten Baseball-Skandale lernen können - Selten hatte die juristische Aufarbeitung sportlicher Verfehlungen einen so großen Nachhall wie zuletzt beim „Sign Stealing“ in der Major League...more

The Volkov Law Group

The Danger of a Hyper-Focused Sales Culture

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We all know that economic incentives are critical to promoting performance.  Going back to the days of Adam Smith, the U.S. economic growth is the result of a basic motivation – hard work can result in significant...more

The Volkov Law Group

Admit It – Your Compliance Program is Not Really “Effective”

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Chief compliance officers are heroes.  They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more

The Volkov Law Group

The Impact of a New CEO

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Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations.  Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more

Thomas Fox - Compliance Evangelist

The Astros Players and Communicating Compliance

The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more

Thomas Fox - Compliance Evangelist

The Elements of Good Judgment: Part 3

Today, I conclude the topic of judgment for compliance professionals. I recently read a Harvard Business Review (HBR) article on the topic by Sir Andrew Likierman, entitled “The Elements of Good Judgment: How to Improve Your...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 5: The Whistleblower and The Amnesty

I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more

The Volkov Law Group

The Future of Compliance – The New Proactive CCO (Part III of III)

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The path of the compliance profession has been remarkable.  Recently, I have seen a number of tweets and postings from compliance thought leaders touting the accomplishments of compliance and the transformation of the...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance-Part 2, Hinch and Luhnow

I am in the midst of a multipart exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. MLB issued...more

The Volkov Law Group

The Future of Compliance: Re-Branding Compliance from Reactive to Proactive (Part I of III)

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As everyone knows, I am an eternal optimist.  Being a cynic always leads to negative energy and results.  As a former federal prosecutor, I am deeply committed to the idea of doing the right thing....more

Thomas Fox - Compliance Evangelist

Farewell to Harrison Dillard and a CCO Using Empathy

As a Chief Compliance Officer (CCO) one of the most powerful tools you have is persuasion. Jenny O’Brien, CCO at UnitedHealthcare, has talked about the techniques that a CCO can use to influence decision making in a company...more

The Volkov Law Group

When Company Supervisors and Managers Engage in Misconduct

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We all know the phrase – “A fish rots from its head.”  A perfectly accurate statement as to how corporate culture can suffer from leadership failures or C-Suite misconduct.  But there is much more to corporate culture than...more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Veiled Lodger and Empathy in Compliance

Over this week, I have reviewed stories from The Casebook of Sherlock Holmes, mining each story for themes and lessons related to the compliance professional, leadership and business ethics. In today’s fifth and final...more

The Volkov Law Group

Ethical Culture Begins with Senior Management

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I tend to repeat myself and when it comes to corporate cultured and ethics, I admit it.  A company without an ethical culture, or at least a commitment to an ethical culture, will be unable to achieve an effective ethics and...more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Blanched Soldier-Learning to Ask For Help

Many compliance professionals in the corporate world work long and it is hard to rise to the senior management level in their organizations. It takes SME, hard work and sometime propitious good fortune to get to the C-Suite...more

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