Donna Boehme and Jim McGrath continually rail against the notion that a ‘rogue employee’ causes the majority of bribery and corruption charges under such laws as the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act. Companies continually claim that they do business ethically and in compliance with such anti-bribery…

Exclusive to Corporate Compliance Insights The Justice Department and SEC were very clear in the FCPA Guidance – they have no patience for a “paper” compliance program. Here is the relevant quote: “DOJ and SEC have often encountered companies with compliance programs that are strong on paper but that nevertheless…

Mastering ethical business leadership

Rock in the pond ethics

Gray areas: When ethics problems are not exactly black or white

When we read a newspaper, watch the TV, there isn’t a day that goes by that there isn’t a report of some leader, in some organization, who is charged with fraud, cheating, lying, etc. Why is that? For me, it’s rather simple. If leaders don’t have a developed moral compass,…

With the concept of leadership under public scrutiny from politicians to CEOs and beyond, the issue of genuine leadership, i.e. what it is, and how is it developed, still eludes many. Leaders are under pressure to reexamine the “who, what, where and why” of a moral basis in order to…

Where does conscience fit into one’s decision-making and what are one’s obligations to conscience in discerning what’s right or wrong? «Conscience,( according to Thomas Aquinas) is the act of determining that which I ought to do or not do, or that I was right or wrong in performing that action.»…

This article originally appeared in Michael Volkov’s blog, Corruption, Crime & Compliance, and is reprinted with permission. Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance. The FCPA Guidance…

One of the topics that has drawn much response from one of my postings on social media was the confusion about the term; compliance/ethics officer. Compliance is not ethics and ethics is not compliance. They are related but not the same. For example, if you look at practically any compliance/ethics…

This article was reprinted with permission from Michael Volkov’s Corruption Crime & Compliance. I continue to be astounded by one simple fact (candidly there are others) – companies do not understand that creating and maintaining an ethical culture improves bottom-line financial performance. A commitment to ethics as an enhancement to…

1. Discern and clarify for yourself on what foundation do you base your ethical decisions. • What’s negotiable/not negotiable; what’s acceptable/not acceptable and why? 2. Realize that people make decisions on the values they hold dear. • Everybody speaks their “truth”. It may not THE truth, but it’s their truth,…