by kwalker | May 23, 2023 | Uncategorized
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,...
by kwalker | Aug 19, 2020 | Uncategorized
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...
by kwalker | Aug 19, 2020 | Uncategorized
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,...
by kwalker | Jun 13, 2020 | Uncategorized
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...
by kwalker | Sep 8, 2019 | Assessment mandates and benefits
For more than a quarter of a century the Antitrust Division of the US Justice Department (the “DOJ”) was an outlier among the components of the DOJ with respect to crediting compliance programs in enforcement matters. That changed on July 11 of this year when, as...
