Compliance Perspectives

HCCA speaker and author Ahmed Salim and host Kortney Nordrum discuss how and why you should be conducting an internal compliance survey in your organization, including:

* Why to conduct surveys in the first place;

* How often you should conduct them;

* How to identify the purpose of your survey and set goals;

* Getting senior leadership buy-in;

* Determining what questions to ask;

* Choosing the survey method and distributing it to your organization;

* The importance of Compliance Officer visibility;

* Collecting and analyzing your data;

* With whom and how to share your findings; and

* Implementing change based off of your survey results.

Ahmed Salim is the Regional Compliance Officer for Presence Health in Chicago, IL. Prior to joining Presence Health, Ahmed was the Compliance Officer for Sutter Health Tracy & Los Banos, California. Also, Ahmed was the Risk & Compliance Manager and Privacy Officer at Lodi Health. Ahmed earned his Juris Doctor degree from Western Michigan Cooley Law School.

For a sample survey please contact Ahmed at: [email protected]

To view slides from Ahmed’s 2016 Compliance Institute presentation on Conducting an Internal Compliance Program Survey, click here: http://bit.ly/2a9iZmE

 

Tom and Roy continue their lively back and forth in this episode. Listen as they discuss:

* Victimization and the value of personal responsibility;

* Standing up for your principles;

* The idea that you can make your sales goals without breaking the law;

* Roy translates wink wink, nod nod, lie, cheat, steal into helpful compliance advice;

* Seeing ghosts;

* Tom channels Ronald Reagan;

* Roy gets on a high horse;

* What ethics and K-cups have in common;

* The myth – or not – of the rogue employee; and

* The universal reason why compliance programs fail.

Thomas Fox has practiced law in Houston for 30 years. He is now the Compliance Ambassador for the Red Flag Group.Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His seminal book, “Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program” is widely viewed as one of the top one volume books on the nuts and bolts of compliance. He is one of the top leaders in social media in compliance, blogging, podcasting, writing and speaking across the globe on anti-corruption and anti-bribery compliance programs.

Roy Snell ([email protected]) is the CEO of the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE), which together now total more than 15,000 members. Roy was a co-founder and the organization’s first President. He has developed numerous partnerships with government, industry, and other professional associations, and he has facilitated collaboration between the compliance/ethics profession and the enforcement community. Roy has a Masters degree in Health and Human Services Administration.

Through his work with the two associations, he has overseen the development of compliance and ethics books, manuals, videos, conferences and audio conferences. He has been a regular speaker in the compliance profession for more than ten years and has spoken internationally for the United Nations on compliance and ethics. He is a Certified Compliance and Ethics Professional (CCEP)®.

Roy writes more than 25 compliance articles annually and has written for several international publications, including European CEO and The European Business Review. Roy is the co-editor of the Health Care Compliance Professional’s Manual and serves as editor, co-editor and advisory board member of several other books, magazines and newsletters. He has served as a source for many media reports, including national publications such as the Wall Street Journal, Forbes Magazine and Business Week. He has been quoted in international publications such as Financial Times and Ethical Corporation.

Recorded live at HCCA’s 20th Anniversary Compliance Institute, HCCA Board Member, Margaret Hambleton, and host Kortney Nordrum discuss the important first steps in building a compliance and ethics program (hint: it’s a risk assessment), including:

* Three steps to build your programs and perform yearly checkups;

* Why you always start with a risk assessment;

* Why you need to be as smart about your business as your CEO;

* How to assess and prioritize risk;

* Knowing how and where to audit in new and established programs;

* Building a work plan;

* Getting buy-in from your board (even if it means scaring them); and

* The ins and outs of risk appetite.

Margaret Hambleton, MBA, CHC, CHPC is Vice President, Corporate Compliance Officer for Dignity Health (formerly known as Catholic Healthcare West), based in Pasadena, California.  Ms. Hambleton responsibilities include managing Compliance operations, with responsibility for ensuring system wide transparency and compliance with all laws and regulations and developing effective, cohesive, and financially prudent compliance strategies with Dignity Health Board of Director’s Audit & Compliance Committee.  She was formerly the Senior Vice President Ministry Integrity and Chief Compliance Officer for St. Joseph Health System, based in Irvine, California.  Her responsibilities included oversight of the Corporate Responsibility Program throughout the health system and its ministries.  Ms. Hambleton reported regularly to the SJHS Board on the effectiveness of the program and materially significant compliance risks to the organization.  She ensured that appropriate and effective goals were developed, implemented, and monitored in accordance with governmental standards and requirements, and the organizations mission and values.

Before joining St. Joseph Health System, Ms. Hambleton was System Director of Corporate Compliance at Catholic Healthcare West, where she was responsible for corporate compliance programs for 11 hospitals in California.

Previously, Ms. Hambleton served as Risk Manager, responsible for claims management, risk financing, and loss prevention at two hospitals in Southern California.  In addition, she served as a Director of Human Resources, responsible for the direction and execution of all human resources functions, including payroll, policy and procedures, compensation, benefits, recruitment, employment, employee relations, and employee health and safety.

Ms. Hambleton has been an active member in the Healthcare Compliance Association (HCCA) since 2000 and is currently a member of the HCCA Board of Directors.  Ms. Hambleton has lectured for HCCA on topics in corporate compliance, risk management, risk assessment processes, and the role of quality in healthcare compliance.

Ms. Hambleton received the Certified Professional in Healthcare Risk Management designation in June 2000, became certified in Healthcare Compliance in 2003, and became certified in Healthcare Privacy Compliance in 2009.  She received her Master’s Degree in Business Administration in 1984 from the University of Phoenix and her Bachelor of Arts in Sociology from California State University, Northridge in 1982.

Tom and Roy continue their conversation in Houston at SCCE’s Utilities & Energy Compliance Conference. In this episode they discuss board engagement, including:

* Roy’s list of questions every board should be asking the Chief Compliance Officer;

* The similarities of compliance programs and breathing air;

* Some sirens in the background to keep us on our toes;

* Roy says the word “malingering”;

* The essentials of board engagement;

* Why you should never ask Tom what keeps him up at night;

* Your new favorite PowerPoint presentation; and

* What board support looks like.

Roy’s List of Questions for Governing Bodies:

 

Roy’s full presentation:

 

Thomas Fox has practiced law in Houston for 30 years. He is now an Independent Consultant, assisting companies with anti-corruption and anti-bribery compliance. He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was previously division counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division.

Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His second book, “Best Practices Under the FCPA and Bribery Act” was released in April, 2013. His latest work is an eBook entitled, “GSK in China: A Game Changer for Compliance”. He writes and lectures across the globe on anti-corruption and anti-bribery compliance programs.

Roy Snell ([email protected]) is the CEO of the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE), which together now total more than 15,000 members. Roy was a co-founder and the organization’s first President. He has developed numerous partnerships with government, industry, and other professional associations, and he has facilitated collaboration between the compliance/ethics profession and the enforcement community. Roy has a Masters degree in Health and Human Services Administration.

Through his work with the two associations, he has overseen the development of compliance and ethics books, manuals, videos, conferences and audio conferences. He has been a regular speaker in the compliance profession for more than ten years and has spoken internationally for the United Nations on compliance and ethics. He is a Certified Compliance and Ethics Professional (CCEP)®.

Roy writes more than 25 compliance articles annually and has written for several international publications, including European CEO and The European Business Review. Roy is the co-editor of the Health Care Compliance Professional’s Manual and serves as editor, co-editor and advisory board member of several other books, magazines and newsletters. He has served as a source for many media reports, including national publications such as the Wall Street Journal, Forbes Magazine and Business Week. He has been quoted in international publications such as Financial Times and Ethical Corporation.

Stephen Paskoff, President and CEO at Employment Learning Innovations, Inc. and host Kortney Nordrum discuss big shots and how to bring them back in line, including:

* Why big shots are tolerated;

* Levels of big shot risk – from unprofessional to illegal;

* How to hold big shots accountable (along with everyone else);

* Building an open culture and why it’s important;

* Why modeling behavior really works (monkey see-monkey do applies to grown ups); and

* Why none of this counts if you don’t build a business case.

Stephen M. Paskoff, Esq., is the founder, president and CEO of ELI®, a learning and consulting company that teaches and advises on professional workplace conduct, helping clients translate their values into behaviors, increase employee contribution, build respectful and inclusive cultures, and reduce legal and ethical risk. 

Mr. Paskoff is a nationally recognized speaker and author on workplace legal issues. He has written extensively on topics related to workplace compliance and legal issues and how to affect culture change in order to build lawful, professional operations that align with an organization’s mission and values. He has been named the highest-ranking speaker at the national conference of the Society for Human Resource Management (SHRM) and has been selected to speak at a number of other national conferences including::

The American Bar Association (ABA)

The Society of Corporate Compliance and Ethics (SCCE)

The Health Care Compliance Association (HCCA)

The American Society for Training and Development (ASTD)

Child Health Corporation of America (CHCA)

The Risk Management Foundation for the Harvard Medical Institutions

In addition, he was the founding Co-Chair of the ABA’s Compliance Training and Communication Subcommittee which explores best practices in training methodology as well as overall strategies for implementing learning and communication plans to maintain corporate compliance. He has served on the Editorial Board of Workforce Management magazine and is a regular contributor to The Conference Board’s Human Capital Exchange.

Stephen Paskoff and ELI have appeared on or been interviewed by a variety of national media outlets, including: ABC’s 20/20, CNBC, Christian Science Monitor, Corporate Legal Times, Corporate University Review, Forbes, Fortune, Fox News, HR Executive Magazine, HR Magazine, HR News, HR Reporter, Inc. Magazine, Industry Week, Workforce Management, The Los Angeles Times, The New York Times, Training Magazine, and USA Today.

He is the author of the book Teaching Big Shots to Behave and Other Human Resource Challenges. In early 2016, his next work Civility Rules will be released.

Prior to establishing ELI® in 1986, Mr. Paskoff was a trial attorney with the Equal Employment Opportunity Commission and a partner in a management law firm. He is a graduate of Hamilton College and the University of Pittsburgh School of Law and is a member of the Pennsylvania and Georgia bars.

You may find Stephen and ELI on the ELI website.

Tom and Roy continue their conversation in Houston at SCCE’s Utilities & Energy Compliance Conference. In this episode:

* Hotlines and why publicizing them is important;

* Taking advantage of all the tools in the toolbox;

* How to make compliance a verb;

* Why Roy says to go big or go home;

* Communication as a quality compliance should have;

* Using ideas, not excuses;

* Why you want spiderwebs in your compliance department;

* Tom’s Tip: If you’re in front of the DOJ, make sure your hotline works; and

* Roy and Tom get to the bottom of this trust but verify thing.

Thomas Fox has practiced law in Houston for 30 years. He is now an Independent Consultant, assisting companies with anti-corruption and anti-bribery compliance. He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was previously division counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division.

Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His second book, “Best Practices Under the FCPA and Bribery Act” was released in April, 2013. His latest work is an eBook entitled, “GSK in China: A Game Changer for Compliance”. He writes and lectures across the globe on anti-corruption and anti-bribery compliance programs.

Roy Snell is the CEO of the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE), which together now total more than 15,000 members. Roy was a co-founder and the organization’s first President. He has developed numerous partnerships with government, industry, and other professional associations, and he has facilitated collaboration between the compliance/ethics profession and the enforcement community. Roy has a Masters degree in Health and Human Services Administration.

Through his work with the two associations, he has overseen the development of compliance and ethics books, manuals, videos, conferences and audio conferences. He has been a regular speaker in the compliance profession for more than ten years and has spoken internationally for the United Nations on compliance and ethics. He is a Certified Compliance and Ethics Professional (CCEP)®.

Roy writes more than 25 compliance articles annually and has written for several international publications, including European CEO and The European Business Review. Roy is the co-editor of the Health Care Compliance Professional’s Manual and serves as editor, co-editor and advisory board member of several other books, magazines and newsletters. He has served as a source for many media reports, including national publications such as the Wall Street Journal, Forbes Magazine and Business Week. He has been quoted in international publications such as Financial Times and Ethical Corporation.

Tom and Roy got together at SCCE’s Utilities & Energy Compliance Conference and recorded some of their conversations. In this episode:

* Roy’s essential elements of a compliance program;

* What separates compliance officers from all who came before;

* Why effective leaders hate vacuums;

* To whom should the CCO report;

* Conflicts of Interest;

* Why farmers and compliance officers are the same – but only one hates silos;

* Compliance programs as contagions (and that’s a good thing); and

* Why you should let others do your work.

Thomas Fox has practiced law in Houston for 30 years. He is now an Independent Consultant, assisting companies with anti-corruption and anti-bribery compliance. He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was previously division counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division.

Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His second book, “Best Practices Under the FCPA and Bribery Act” was released in April, 2013. His latest work is an eBook entitled, “GSK in China: A Game Changer for Compliance”. He writes and lectures across the globe on anti-corruption and anti-bribery compliance programs.

Roy Snell is the CEO of the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE), which together now total more than 15,000 members. Roy was a co-founder and the organization’s first President. He has developed numerous partnerships with government, industry, and other professional associations, and he has facilitated collaboration between the compliance/ethics profession and the enforcement community. Roy has a Masters degree in Health and Human Services Administration.

Through his work with the two associations, he has overseen the development of compliance and ethics books, manuals, videos, conferences and audio conferences. He has been a regular speaker in the compliance profession for more than ten years and has spoken internationally for the United Nations on compliance and ethics. He is a Certified Compliance and Ethics Professional (CCEP)®.

Roy writes more than 25 compliance articles annually and has written for several international publications, including European CEO and The European Business Review. Roy is the co-editor of the Health Care Compliance Professional’s Manual and serves as editor, co-editor and advisory board member of several other books, magazines and newsletters. He has served as a source for many media reports, including national publications such as the Wall Street Journal, Forbes Magazine and Business Week. He has been quoted in international publications such as Financial Times and Ethical Corporation.

Jay Rosen, Vice President, Legal & Corporate Language Solutions for Merrill Corporation and host Kortney Nordrum discuss the importance of accurate translations in compliance, including:

* Why accurate translations matter;

* What is a certified translation;

* Why Becky down the hall who spent a summer in Paris shouldn’t translate your documents;

* 3 good excuses why you don’t think you need to hire a translation company (and why you may be wrong);

* How to build a solid 3-5 year translation plan;

* Recording your translation plan for audit purposes;

* Why using free online sites may be more 1984 than 2016;

* What you should look for when hiring a translator/linguist; and

* Are translations a right or a privilege?

Jay utilizes his experience, deep industry knowledge and consultative approach to provide cost effective translation solutions for global investigations, patent and IP litigation, FCPA, Ethics and Compliance localization and cross-border matters.   He is particularly interested in helping companies to proactively deal with foreign language based investigations of potential Foreign Corrupt Practices Act (FCPA) exposure whether through “whistleblower” initiated, self investigation, pre-M&A due diligence or designing global monitor and compliance localization solutions.

Jay will be speaking at the 2016 Compliance & Ethics Institute, September 25-28, 2016 in Chicago, Illinois. Jay’s session will focus on Global ABC and FCPA Benchmarks, Best Practices, and Bootcamps. For more information go to www.complianceethicsinstitute.org

At the 2014 Society for Corporate Compliance & Ethics Compliance & Ethics Institute, Jay hosted a panel discussion with Melissa Paul from FedEx and Eric Morehead from NYSE Governance Services on  “Making the Code of Conduct Resonate Across Borders”.

Jay often speaks on the subject matter of “Best Practices in Translation and Language Technology for Foreign Language Intensive Investigations” and has presented at both the San Jose and San Francisco ACFE Chapters.

Jay has contributed video content to the SCCE’s ComplianceVideos series and has appeared on NSYE Governance Services Inside Compliance interview series.

He has provided guest blogs for Tom Fox’s FCPA Compliance and Ethics Blog on subjects ranging from  “How Can Global Corporations Afford (or Afford Not) to Employ Professional LSPs?”, “Ethics, Compliance and School Drop-Off Etiquette”, “Don’t Get Lost in [FCPA] Translation” to “Best Practices for Localizing Corporate Ethics and Compliance Policies”.

Jay’s article on “Translation considerations for global internal investigations, ethics and compliance matters” appeared in the November/December 2012 issue of Compliance & Ethics Professional

Find Jay on LinkedIn: https://www.linkedin.com/in/jayrosen

You may also contact Jay at [email protected] or 310-407-8184.

If you have suggestion or questions for the Compliance Perspectives Podcast, please email Kortney at [email protected]

Tom and Roy got together at SCCE’s Utilities & Energy Compliance Conference in Houston last week. In this episode:

* Tom rubs it in that Houston is warmer than Minneapolis;

* Utilities & Energy conference wrap-up from their perspectives;

* Why you should know Sam and Bill;

* Opportunities for service with the SCCE;

* Roy’s insider tips for getting your submissions selected for speaking at SCCE/HCCA conferences;

* The scariest thing Tom heard last week;

* The realization that the only thing you really have is your reputation;

* Why you should invite yourself to your business associates’ family dinners;

* Training for interpersonal skills and influence;

* Kristy Grant-Hart bringing a positive outlook to compliance;

* Wal-Mart’s bribery investigation; and

* Compliance redemption; and

* Why you should donate to HCCA’s Silent Auction to benefit America’s Fund – link: America’s Fund Silent Auction

* More information about America’s Fund: www.americasfund.org

Thomas Fox has practiced law in Houston for 30 years. He is now an Independent Consultant, assisting companies with anti-corruption and anti-bribery compliance. He was most recently the General Counsel at Drilling Controls, Inc., a worldwide oilfield manufacturing and service company. He was previously division counsel with Halliburton Energy Services, Inc. where he supported Halliburton’s software division and its downhole division.

Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His second book, “Best Practices Under the FCPA and Bribery Act” was released in April, 2013. His latest work is an eBook entitled, “GSK in China: A Game Changer for Compliance”. He writes and lectures across the globe on anti-corruption and anti-bribery compliance programs.

Roy Snell is the CEO of the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE), which together now total more than 15,000 members. Roy was a co-founder and the organization’s first President. He has developed numerous partnerships with government, industry, and other professional associations, and he has facilitated collaboration between the compliance/ethics profession and the enforcement community. Roy has a Masters degree in Health and Human Services Administration.

Through his work with the two associations, he has overseen the development of compliance and ethics books, manuals, videos, conferences and audio conferences. He has been a regular speaker in the compliance profession for more than ten years and has spoken internationally for the United Nations on compliance and ethics. He is a Certified Compliance and Ethics Professional (CCEP)®.

Roy writes more than 25 compliance articles annually and has written for several international publications, including European CEO and The European Business Review. Roy is the co-editor of the Health Care Compliance Professional’s Manual and serves as editor, co-editor and advisory board member of several other books, magazines and newsletters. He has served as a source for many media reports, including national publications such as the Wall Street Journal, Forbes Magazineand Business Week. He has been quoted in international publications such as Financial Times and Ethical Corporation.

Ethical and effective communications expert, Jane Mitchell and host Kortney Nordrum discuss the importance of engaging middle management, including:

* Why swimming with sharks may not be a bad thing;

* Why corporate communication is key for middle managers;

* Whether middle management is best compared to marzipan or blancmange;

* Training managers to manage;

* Why everyone keeps talking about engagement;

* Reaching the middle and speaking their language;

* Cultural awareness; and

* Storytelling for effective communication.

Jane began her early professional career in UK television broadcasting at the BBC on such TV icons as Tomorrow’s World, Grange Hill and Blue Peter. She made a leap into the outside world and began producing award-winning corporate films and videos, which led into helping clients develop a strategic approach to internal communications.

Her work with Rolls-Royce plc took her into the area of communicating Global Codes of Ethics where she was responsible for leading a small in-house team launching and embedding the Code across the company. Since then Jane has continued to work with organizations helping them to make the links between Codes, values, behaviours, ethical leadership, decision-making. Her focus is on encouraging people to understand their individual responsibilities in often challenging corporate environments.

Subsequently, Jane worked with BAE Systems and Diageo plc on various aspects of their ethics programmes and with the Institute of Business Ethics (IBE), she helped to develop a newly formed Cable & Wireless Worldwide Company Code.

Since 2005, Jane has operated JL&M Ltd., working with clients including BP, PwC, KPMG, Serco, and Schlumberger for whom she has worked on a variety of aspects of their ethics programs. She has also worked with the US-based non-profit, Graduate Management Admission Council (GMAC) advising them on the creation and embedding of their inaugural Code of Ethical Behavior.

In Jane’s own words:

“I advise, ‘guide’ and support (some might say challenge), leaders in organisations large and small, as they find ways to embed their ethics, values-based leadership and behaviours. At the heart of my work is the principle that people willingly take responsibility for their own behaviour and actions at work when they understand what the ‘corporate’ ambition is and how they can contribute to it, and are recognised for that effort. There is wisdom, knowledge and enthusiasm at every level of an organisation and when dots are connected effectively the insights everyone gains can be harnessed to drive real and positive change. It’s connecting the dots that is the key.”

Find Jane on LinkedIn: https://www.linkedin.com/in/janelmitchell

If you have suggestion or questions for the Compliance Perspectives Podcast, please email Kortney at [email protected]