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 Jeff Kaplan | May 23, 2023 | Uncategorized
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...
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 | 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....
