Training the Board

Training the Board

Although many companies have well-developed procedures and practices for reporting information to their boards regarding their compliance and ethics programs, training members of the board is an area that organizations continue to grapple with.  Indeed,...
More on reverse conflicts of interest

More on reverse conflicts of interest

A company enters into a complex business arrangement where one of its managers has a relationship with the other entity.  The relationship is fully disclosed and approved pursuant to company policy on COI waivers.  After some  time, the arrangement runs into business...
Assessing Codes of Conduct

Assessing Codes of Conduct

Codes of conduct are often described as the most important document in a compliance program. Codes help set the right tone for compliance and ethics (“C&E”) programs.  They are educational tools that should serve to raise awareness and understanding of important...
Program Structure

Program Structure

In the posts collected here we will discuss assessment-related issues concerning a) various types of C&E program roles and reporting relationships, including those involving the board of directors; senior management; C&E department management; other staff,...
Revisions to DOJ Program

Revisions to DOJ Program

On June 1, 2020, the U.S. Department of Justice (“DOJ”), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs” (“the  2020 Update”) to provide increased clarity on several of the key questions prosecutors might ask in assessing...