by kwalker | Jun 8, 2019 | Methodologies
The modern era of corporate compliance began on November 1, 1991, when the Federal Sentencing Guidelines for Organizations (the “FSGO”) – the first set of general standards for assessing the efficacy of what were then called “program[s] to prevent and detect...
by kwalker | Feb 20, 2019 | Methodologies
Behavioral economics is a school of social science that teaches that we are not as rational as we think. The application of that learning to the realm of ethics is sometimes called “behavioral ethics,” which is a social science that teaches that we are not as ethical...
by kwalker | Jan 7, 2019 | Culture
Research conducted over the past twenty years has provided an evidentiary basis for what has – for just as long – been accepted wisdom in the E&C community: that an ethical organizational culture is even more effective than a strong E&C program at preventing...
by kwalker | Dec 10, 2018 | Uncategorized
Legal guidance in the area of C&E program assessments accords with professional wisdom in this area, emphasizing the importance of periodic assessments to an effective program. In this post, we review a few of the relevant legal standards from U.S. authorities....
by kwalker | Oct 23, 2018 | Methodologies
A threshold issue which often arises in conducting C&E program assessments is to what extent the process and report should be treated as confidential. There are two components to this question, the first of which concerns the use of the company’s attorney-client...
