Compliance into the Weeds

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into horrific corporate conduct engaged in by Hacienda Healthcare in Arizona over the past few months. Our discussion provides insights into failures at the Board oversight level, corporate governance, CEO, senior management and CCO position.  Some of the highlights include: Ø What are the background facts of the matter?Ø How could the facility allow the rape of an incapacitated patient who is in a permanent vegetative state?Ø Why did the professional investigator brought into to investigate the crime resign so noisily?Ø Why was there such a complete total and utter failure by the Board on oversight?Ø What, if any, are the potential criminal charges which might be filed?Ø Where was compliance? For additional reading see Matt’s blog post Governance Nightmare in Arizonaon Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving surrounding New England Patriots owner Robert Kraft who has been charged with solicitation of prostitution, what it means for both Kraft and the NFL and the compliance response.   Some of the highlights include: Ø What are the background facts of the matter?Ø What has been the response of the NFL? Will it investigate or leave it to the public authorities?Ø What are other criminal charges involving NFL owners and what was the NFL response?Ø What are the key employee/CEO risks for an organization?Ø How much private conduct is really public in this age of social media?Ø Why is compliance the only response? For additional reading see Tom’s blog post Robert Kraft, the NFL and Complianceon the FCPA Compliance and Ethics Blog. Learn more about your ad choices. Visit megaphone.fm/adchoices

Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent imbroglio involving (at least as of now) current Governor of Virginia, Ralph Northam and the pictures involving Northam in blackface and KKK robes.    Some of the highlights include: Ø What is ethical leadership?Ø Why is Northam following the Trump playbook?Ø How and why employees take their cues around ethics from their leaders?Ø Why are employees looking to work for companies with a culture of accountability?Ø Why should the CCO have an ethical role in an organization? For additional reading see Matt’s blog post Northam and Ethical Accountabilityin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program.You can also copy and paste the URL below into your internet browser:https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITYAll responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy). Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into recent blown call in the Saints-Rams NFC. We consider the (non) response from the NFL under the rubric of internal controls.   Some of the highlights include: Ø What is risk and how should it be considered?Ø Who are the stakeholders for professional football? Who are the stakeholders for your organization?Ø Does your risk increase the closer you get to the final goal? (IE., playing for the Super Bowl)Ø If a control failure can lead to a material adverse event, shouldn’t you have a compensating control?Ø Should an organization like the NFL even care about getting it right? For additional reading see Matt’s blog post Of Blown Calls and Internal Controlin Radical Compliance.  Share Your Compliance Expertise and Help Those in Need!We need your expertise on ethics & compliance programs! If you’re involved in managing employee policies & procedures, a hotline/incident management program, training initiatives or third party risk management, please share your thoughts on your program effectiveness, success measurements, and key activities and goals for this year by taking part in NAVEX Global’s 2019 Future of Compliance Report survey.Click here to complete the survey.For every complete, $10 (USD) will be donated on your behalf to the charity of your choosing from the following charities: UNICEF, Operation Smile, St. Jude Children’s Hospital, Humane Society, Wounded Warrior Project,Médecins Sans Frontières, or Rainbow Trust Children’s Charity. Also, as a thank you for your participation in this annual study, you’ll get access to this valuable benchmark data to create a more effective compliance program.You can also copy and paste the URL below into your internet browser:https://na1se.voxco.com/SE/?st=4P4BV59nKuYZVVwz2mHGZPBTRrG4NjahAP%2FlgrTzTYE%3D&urlimport=1&questlist=source&source=4 COMMITMENT TO ANONYMITYAll responses are confidential and will be reported only in aggregate form. Individual data will NEVER be shared with any other party (privacy policy). Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into some of the difficulties around distributors in anti-corruption compliance.   Some of the highlights include: Ø The recent Polycom FCPA enforcement action highlighted several FCPA enforcement actions from 2018 involving distributors.Ø How do discounts, coupons, rebates, and sales devices circulate among your company, distributors, and end customers? Distributors present these and other issues separate from sales agents and employees.Ø What do the Sanofi and Stryker enforcement actions tell us around compliance?Ø Why does Document Document Document continue to be a mantra for anti-corruption compliance?   For additional reading see Matt’s blog posts Distributors, FCPA, and Internal Controls — Lessons for Anti-Bribery & Corruption Programsin Navex Global’s Ethics and Compliance Matters For more on the Polycom FCPA enforcement action, see Tom’s blog post, “Follow the Money Through Distributors”  Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into management review controls.   Some of the highlights include: Ø Will the PCAOB up its game in this area?Ø When will the SEC provide updated guidance on the issue? Ø Will it be up to COSO to formulate an appropriate new standard? Ø How does all of this apply to the compliance professional?  For additional reading see Matt’s blog posts Deloitte Inspection Report ReleasedandTalking Compliance Analytics at AB-InBevin Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into a recent blog post by Matt on his top nine story lines for 2019. We slice and dice them and try to consider how they will impact the compliance profession going forward.   Some of the highlights include: Ø A US data privacy law and GDPR enforcement.Ø What do restive employees have to do with Adam Smith? Ø Private equity sees money to be made in the GRC vendor space. What will it mean for compliance? Ø Forgiveness seems to be the byword for the DOJ in 2018 FCPA enforcement. Will it encourage more self-disclosure?   For additional reading see Matt’s blog post “Nine Compliance Issues for 2019” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent announced Polycom Inc. FCPA enforcement action. We both blogged on it and we bring two difference perspectives to this matter. I take a deep dive into the nuts and bolts lessons learned for the compliance practitioner. Matt takes a step back and considers the larger picture of corporate culture, corrupt CEOs and how these can lead to the destruction of the company.   Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø How the CEO’s corrupt nature permeated the entire organization. Ø Oversight means more than simply asking questions and accepting the proffered answers. Ø Data analytics are critical for a best practices compliance program going forward.  For additional reading see Matt’s blog post “Many Lessons in Polycom FCPA Case” in Radical Compliance.  See also Tom’s blog “Following the Money Through Distributors” in the FCPA Compliance and Ethics Blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent report in the New York Timesabout the settlement of CBS with the actor Eliza Dushku over allegations of retaliation for reporting sexual harassment by CBS series star in the TV drama Bull, Michael Weatherly. The entire episode exposed the culture at CBS and the failure in the structure of the company’s compliance program.  After reporting unwanted and/or inappropriate behavior, Dushku’s character was literally written out of the series. She went to mediation over the retaliation for her internal reporting. In a formal mediation process, CBS’s attempted to assassinate her character but the evidence presented backfired on CBS as it proved the harassment. Worse yet the character assassination attempts were made by a CBS lawyer who is also the company’s Chief Compliance Officer.  Some of the highlights include: Ø There were two forces at work which amplified the negative actions and effects.Ø The interest of CBS legal was to attack the accuser and settle the lawsuit. Ø The interest of a CCO should have been was to prevent, detect and remediate the issue so that it would create a speak up culture. Ø When you subordinate an ethical culture to a legal position, it works to destroy employee trust and morale.  For additional reading see Matt’s blog post “CBS Compliance, Culture Under Fire” in Radical Compliance.  Learn more about your ad choices. Visit megaphone.fm/adchoices