In this episode, Richard Lummis and I consider the recent revelations which came to light that during the tenure of the former Chief Executive Officer, Jeff Immelt, he had an empty plane fly behind his jet on corporate trips. There were several points a Board of Directors can learn from these revelations going forward. 

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In this episode, Richard Lummis and I consider the recent revelations which came to light that during the tenure of the former Chief Executive Officer, Jeff Immelt, he had an empty plane fly behind his jet on corporate trips. There were several points a Board of Directors can learn from these revelations going forward. 

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This requirement is more than simply the ubiquitous ‘tone-at-the-top’ as it focuses on the conduct of senior management. The Justice Department wants to see a company’s senior leadership actually doing compliance. The DOJ asks if company leadership has through their words and concrete actions brought the right message of doing business ethically and in compliance to a company. How does senior management model its behavior on a company’s values and finally how is such conduct monitored in an organiza

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In this episode, Matt Kelly and I take a look at some of the more intriguing issues in compliance and ethics, FCPA and greater GRC issues in the new year of 2018.

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Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an important, key step as it will allow you to have full visibility of your compliance risks through a longer life cycle.

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In this episode, I visit with SCCE incoming President Gerry Zack about his new role with the organization.

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Jay and I take things in a different direction this week. We take the top five podcasts from 2017 and each of us, gives a highlight from that episode to highlight some of the key compliance issues from 2017, for our year end wrapup edition.

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Over the next 31 days, I will be exploring the best way to more fully operationalize a compliance program using the DOJ resources. Join me as we engage in 31 days to a more effective compliance program.

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This entry provides a wrap up on written standards, with a discussion on policies on cybersecurity. Regarding policies on cybersecurity, it has become so critical for corporation that the CCO and many compliance practitioners are now required to deal this issue.

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The next area for policies is extortion payments, which are completely exempted out of the FCPA. Extortion payments are made for any action which threatens or demands payment for life, liberty, or health. These should be exempted out from your facilitation payments and your compliance program through specific language. As a compliance professional, you need to make sure employees understand they need to do whatever they must to get themselves out of such a situation

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