Compliance Beat

Drawing again from his upcoming presentation at the SCCE Compliance and Ethics Institute on September 21, 2021, Eric discusses some key criteria to consider when evaluating or benchmarking a code of conduct.

Eric discusses the upcoming 20th Annual SCCE Compliance and Ethics Institute and his presentation "Lessons from Sixty Code of Conduct Projects: What Are Five Things You Need for a Best-In-Class Code?" (scce-2021-cei-brochure.pdf (corporatecompliance.org) and, in particular, we focus on some key points to keep in mind when you are going to launch your new (or revised) code of conduct.

In this episode Eric discusses the upcoming SCCE CEI event in Las Vegas (20th Annual Compliance & Ethics Institute | SCCE Official Site (corporatecompliance.org)), and in particular, one of the sessions he will be co-presenting with Kathleen Grilli from the US Sentencing Commission, "Thirty Years of Organizational Sentencing Guidelines: Looking Back and Looking Forward". In particular, Eric discusses three data points from the USSC's dataset (Sourcebook 2020 | United States Sentencing...

This time Eric spends a little time discussing why a company might want to have a third-party code of conduct, rather than relying only on their employee code of conduct. We discuss some of the reasons a third-party code is potentially a good idea, who the audience might be and what are some of the topics you might want to cover.

This time Eric reviews the top mistakes he's seen clients and others make when tackling an code of conduct revision or rewrite process. Codes of Conduct are the foundation of any effective program and taking the appropriate care and time to complete a code revision project is the key to success.

In this episode Eric discusses some considerations for a successful code of conduct launch. Often organizations spend a lot of time, effort and resources on revising and improving their code of conduct only to have little in the way of a launch effort. Eric discusses some ideas to avoid a failure to launch.

It's been a year! We've seen challenges and changes -- and we're still not completely out of the woods yet. In this episode Eric talks about three of those seemingly permanent changes that compliance and ethics programs have had to deal with and also discusses three things that are definitely not going to change.

After a extended hiatus, we're back! We're looking for your feedback on what to cover and what you'd like to hear about in the weeks going forward. Email us at: eric@moreheadconsulting.com

The world has changed since our last episode. Eric has some ideas for newly remote compliance officers handling newly remote workers. Communication is key, and the compliance team needs to make a special effort to be heard and involved.

This time Eric discusses three primary reasons an organization might want to work with a third party to conduct a compliance program assessment.

This time Eric walks through some categories to benchmark your code of conduct. Organizations are expected to regularly examine the effectiveness of their written standards and there are some common areas to review when taking stock of your code.

This time Eric discusses three keys for a successful conflicts of interest compliance process. Eric discusses communication, disclosure, certification and tools that organizations can use to better address conflicts of interest risk.

There are many ingredients for a successful compliance program assessment, but in this episode Eric focuses on three key components that are sometimes overlooked when an organization is either conducting their assessment internally or looking to a third-party to help them with a review.

This time Eric talks anonymous reporting mechanism. What is actually required? What does reporting data show an compliance officer? What is the most effective reporting channel for an organization? We talk about these important questions and debunk a few myths about anonymous reporting.

This time Eric spends some time talking about some practical considerations for organizations to consider when planning or revising their "informal" compliance communication program. This area of compliance has been changing quite rapidly and expectations are often high. To avoid disappointing results it is important for compliance officers and others charged with communication responsibilities to carefully consider the goals and realities of proposed program.

This is the second in a two-part discussion about perception and retaliation. This time we talk about solutions. How can an organization address the lingering perception of retaliation? We spend a few minutes looking at the data and discussing what you might do at your organization to address these issues.

This time Eric talks about retaliation. What does retaliation look like in an organization? How does perception of retaliation affect reporting? We spend a few minutes looking at the data and discussing what you should expect at your organization.

Getting your managers involved in your compliance program is a best practice and also the most effective way to address compliance culture locally. In this episode Eric talks about three key criteria to consider when putting together a plan for involving managers: training, resources and measurement. Eric discusses some practical ways to implement such a plan.

As more and more compliance professionals join the ranks from other disciplines, it’s important that we reinforce the role of the US Sentencing Commission, and maybe even more importantly, the public’s role in defining the compliance and ethics standards all of our programs are based on. Listen to a short description of what the Sentencing Commission is, and their role in our profession — both past and future. Also, join Eric for a webinar next week on Thursday, November 7th at 1PM ET:...

There’s not a lot of data out there to tell us how the Department of Justice or other regulators view compliance initiatives, or what expectations really are. We know what the guidance tells us, but what happens in the real world when a company’s compliance program is looked at? We can get some indications from Sentencing Commission data that tells us what happens to those unlucky companies that face a Federal judge for sentencing.