In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons:
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September 12, 2014 • Randy Stephens
Last week, the SEC announced its first whistleblower award to an audit and compliance professional. The $300,000 award announcement noted that the recipient had “reported concerns to appropriate personnel within the company, including a supervisor,” but after 120 days, went to the SEC when they believed the company failed to take action. I took away several potential implications and lessons stakeholders might learn from this announcement: For Compliance Officers and Senior Executive Teams
September 2, 2014 • Andrew Foose
A real-life situation recently provided powerful evidence of the value—and effectiveness—of ethics and compliance training and communication. When scientists want to prove the effect of something such as, for example, a new drug, they often conduct a study comparing two groups. Ideally, the two groups are as similar as possible to each other, with the only meaningful difference being the factor being studied (e.g., only one group would get the new drug).
When respondents to the NAVEX Global 2014 Ethics & Compliance Training Benchmark Survey were asked whether each employee in their organization received the ethics and compliance training they need, 75 percent either “agreed” or “strongly agreed” that their employees were covered. However, additional data collected in our survey suggests a startling disconnect between an overall positive perception of training program effectiveness, and concerns about training adequacy for specific audiences—namely supervisors.
August 28, 2014 • Eddy O'Mara
Benchmarking your hotline compliance data against best practices and peer data is an important part of assessing the health of your company’s culture. But not all industry benchmarks are created equal. When deciding which industry benchmarks to compare your organization’s hotline data to, it‘s important to ensure that those benchmarks have been calculated according to best-practice approaches. Best Practice Benchmark Calculation The primary, and simplest, method that many data providers use to generate their hotline benchmarks is to pool data by industry and calculate the average result for each given metric.
August 21, 2014 • Randy Stephens
I was recently in a business lounge at the airport in Atlanta, and was amazed to be bombarded by executives on their cell phones loudly conducting business. Sitting within earshot, I learned that a large manufacturer (I knew which one it was because the person speaking about it was wearing a company-branded polo shirt) just won a major contract, and a company in the healthcare industry is preparing for layoffs. When “Working in Public” Becomes an Insider Trading Policy Violation
August 19, 2014 • Daniel Kline
The United Kingdom’s Parliament has been considering offering whistleblower bounties similar to those offered under the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. A commission formed by the Bank of England and the UK Financial Conduct Authority spent time with U.S. regulators to investigate the benefits and the drawbacks of this type of legislation. The commission’s recommendation back to Parliament? A resounding no! Employees to Bounty Hunters?
August 14, 2014 • Ingrid Fredeen,
More than half (56 percent) of the respondents to the NAVEX Global 2014 Ethics & Compliance Training Benchmark Survey revealed that their top ethics and compliance training concern today is the limited hours available for training their stakeholders. A close second (54 percent) is measuring the effectiveness of training programs, and the third among top challenges is not enough budget (42 percent).
August 12, 2014 • Randy Stephens
A little over a year ago the Rana Plaza factory collapsed and 1,100 garment workers died. This human disaster resulting from questionable construction practices and workplace safety issues focused the eyes of the world on the working conditions of those who supply major retailers. Products manufactured for multinational, brand giants, such as H&M and Kmart, JC Penney and Benetton were found amongst the rubble of the building, which local officials had warned was unsafe.
August 7, 2014 • Andrew Foose
I was challenged recently by a participant during an in-depth webinar on conducting investigations of employee misconduct that I was leading. As I discussed how to assess witness credibility—one of the most difficult challenges investigators face—the participant sent me a message that said, “Not to contradict you, but the Association of Certified Fraud Examiners (ACFE) states that investigators should not rely on their opinion in reaching a conclusion.”