Section 2

Building Your Foundation

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Implement What You Know with Confidence

Discover action-based tools that provide simple steps for program improvement or robust plans for new ways of doing business. 

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Your ethics and compliance program is an ecosystem of moving parts. New laws and regulations, new lines of business, new geographies, mergers and acquisitions become part of a growing enterprise that your compliance ecosystem must support. 

Effective compliance programs are able to deftly navigate these complexities because they have built strong foundations that were developed with the nature of the compliance industry in mind.

This section will give you the expert advice and programmatic best practices to ensure the first steps you take to develop your program are in the right direction. Or if your program is more mature, these resources and insights will give you the necessary guidance to course correct and improve your program’s foundation at whichever stage it is in. 

 

How to Survive a Conflict of Interest

Chapter 12 of The Worst-Case Scenario Survival Guide for Compliance Professionals

Conflicts of interest can be expensive legally and culturally. Knowing the early warning signs can aid in preventing future corruption as well as reducing the perception of conflicts. Learn how you can best survive a conflict of interest.

Tom Fox 06/27/2018

Chapter 12 of The Worst-Case Scenario Survival Guide for Compliance Professionals

Conflicts of interest can be expensive legally and culturally. Knowing the early warning signs can aid in preventing future corruption as well as reducing the perception of conflicts. Learn how you can best survive a conflict of interest.

7. The Bottom Line

This is a serious problem for your company. It involves a basic conflict by the top level of your organization. It points to the need for an independent CCO who does not report to the CEO or general counsel but has a direct line reporting to the chairman of the board of director’s compliance committee. The violation of the CEO may have been a misstep in judgment, but that type of misstep could be very costly for the company in the eyes of regulators and stakeholders.

The conflict of interest policy is a foundational document for every company. If a CEO violates it, the response must be swift and internally consistent with how employees are treated. If the CEO is given special treatment, it will not only destroy the validity of your conflict of interest policy but may well mortally wound your compliance program.  

 

Illustrated by Dex Novak