Corporate

Recent Posts

The IBM Case: FCPA Compliance Programs And Internal Controls
Posted on 21 Mar 2011 by Thomas O. Gorman

There was Congressional testimony last fall to consider possible modifications to the Foreign Corrupt Practices Act. In part the testimony focused on the issue of FCPA compliance procedures as a defense for a business organization. Under current practice... Read More

End of the Annual Compliance and Ethics Training ‘Flea Dip’
Posted on 10 Aug 2011 by Thomas Fox

In an article in the July/August edition of the ACC Docket entitled " Rethinking the Annual Compliance and Ethics Flea Dip ", author James Nortz discusses the annual compliance and ethics training program that most US company's employees... Read More

Johnson & Johnson Becomes the Newest Member of the FCPA Top 10 Settlements List
Posted on 13 Apr 2011 by Thomas O. Gorman

Current trends in FCPA enforcement are evident in the latest settlement with Johnson & Johnson. U.S. v. Depuy, Inc. , (D.D.C. Filed April 8, 2011); SEC v. Johnson & Johnson , Civil Action No. 1:11-cv-00686 (D.D.C. Filed April 8, 2011). To resolve... Read More

Jeannette Rankin, Infosys, Ethics and Compliance
Posted on 9 Nov 2011 by Thomas Fox

Who was Jeannette Rankin and why do we celebrate her today in the context of ethics and compliance? She was the first female to be elected to Congress, as a Representative from Montana in the 1916 elections. In 1917 she was one of 50 votes opposing... Read More

The Convergence of Bear Bryant and Johnny Football – Lessons In Compliance
Posted on 13 Sep 2013 by Thomas Fox

Sedona Arizona is known for its four vortexes, some of those alleged places where the universe has holes in it or overlaps (I can’t remember which). I have been to Sedona but I have never experienced such convergence (or the voids for that matter... Read More

The Compliance and Ethics Program: Outsourcing Inspiration
Posted on 7 Jun 2011 by Thomas Fox

In the June issue of the Harvard Business Review is an article by Alan Grant entitled, " How Customers Can Rally Your Troops ". In this article Grant argues that "End users can energize your workforce better than your managers can."... Read More

Chesapeake Lighthouses and Lighting the Way for Compliance
Posted on 25 Jan 2013 by Thomas Fox

In the winter 2013 issue of the Colonial Williamsburg magazine is an article by Michael Lombardi, entitled " Lighthouses Marked the Shoals of the Commerce Clause ". In this article, Lombardi wrote about four lighthouses authorized by Congress... Read More

Don’t Fold ‘Em: Making the Case for Ethical Leadership
Posted on 17 Aug 2011 by Thomas Fox

In an article published in the June issue of ACC Docket, entitled " Playing the Cards You're Dealt ", James Nortz raised the interesting issue of the lack of company leadership to "create an ethical vision, the moral courage to pursue... Read More

Naval Theorists and the Measurement of Compliance
Posted on 17 Jan 2014 by Thomas Fox

If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great battle concept. If you are Corbettian... Read More

Johnson & Johnson Deferred Prosecution Agreement-Part II: Compliance Program Best Practices
Posted on 12 Apr 2011 by Thomas Fox

Yesterday we reviewed the background facts of the Johnson & Johnson (J&J) Deferred Prosecution Agreement (DPA) and the issue of self-reporting. In this posting we will review some of specific compliance program best practices which Johnson... Read More

The Abbey Grange, the Quality of Justice and Codes of Conduct
Posted on 28 Jan 2014 by Thomas Fox

In honor of the return of Sherlock Holmes to PBS with Season 3, I begin a week of Sherlockian themed posts. Today we consider the quality of justice that Holmes discussed in The Abbey Grange , he allowed a man who murdered a wife-abusing husband to go... Read More

Johnson & Johnson, DePuy Pay $76.9M To Settle Foreign Bribery Claims
Posted on 12 Apr 2011 by Tom Moylan

(Mealey's) - Johnson & Johnson (J&J) and subsidiary DePuy International Ltd. will pay $76.9 million to resolve criminal and civil allegations in the United States and in the United Kingdom that they paid kickbacks to doctors in Greece,... Read More

Warren Buffet, Berkshire Hathaway and the End of Armageddon-Some Lessons Learned
Posted on 3 May 2011 by Thomas Fox

We have previously written about the importance of getting your investigation right before publicly announcing the results. In other words, do not allow your CEO, as Renault did, to go on national television and decree that three (former) executives... Read More

How Charles Ponzi Can Inform Your Compliance Program
Posted on 24 Jan 2012 by Thomas Fox

Yesterday, I used some of the wisdom from current CIA Director General David Petraeus to suggest how senior management might move forward with a compliance program. Today I will use a very different individual to help inform your third party due diligence... Read More

How to Engage Employees in Compliance
Posted on 25 Aug 2011 by Thomas Fox

In the September 2011 issue of the Harvard Business Review , in an article entitled " How to Cultivate Engaged Employees " , author Charalambos A. Vlachoutsicos wrote about his experiences in working for a family-owned multi-national organization... Read More

  • Blog Post: The IBM Case: FCPA Compliance Programs And Internal Controls

    There was Congressional testimony last fall to consider possible modifications to the Foreign Corrupt Practices Act. In part the testimony focused on the issue of FCPA compliance procedures as a defense for a business organization. Under current practice those procedures are not a defense but mitigation...
  • Blog Post: Johnson & Johnson, DePuy Pay $76.9M To Settle Foreign Bribery Claims

    (Mealey's) - Johnson & Johnson (J&J) and subsidiary DePuy International Ltd. will pay $76.9 million to resolve criminal and civil allegations in the United States and in the United Kingdom that they paid kickbacks to doctors in Greece, Poland, Romania and Iraq to use the companies'...
  • Blog Post: Johnson & Johnson Deferred Prosecution Agreement-Part II: Compliance Program Best Practices

    Yesterday we reviewed the background facts of the Johnson & Johnson (J&J) Deferred Prosecution Agreement (DPA) and the issue of self-reporting. In this posting we will review some of specific compliance program best practices which Johnson & Johnson agreed to implement. I. Attachment...
  • Blog Post: Johnson & Johnson Becomes the Newest Member of the FCPA Top 10 Settlements List

    Current trends in FCPA enforcement are evident in the latest settlement with Johnson & Johnson. U.S. v. Depuy, Inc. , (D.D.C. Filed April 8, 2011); SEC v. Johnson & Johnson , Civil Action No. 1:11-cv-00686 (D.D.C. Filed April 8, 2011). To resolve the case with DOJ and the SEC the company...
  • Blog Post: The Compliance and Ethics Program: Outsourcing Inspiration

    In the June issue of the Harvard Business Review is an article by Alan Grant entitled, " How Customers Can Rally Your Troops ". In this article Grant argues that "End users can energize your workforce better than your managers can." His basic thesis is that employees are highly...
  • Blog Post: End of the Annual Compliance and Ethics Training ‘Flea Dip’

    In an article in the July/August edition of the ACC Docket entitled " Rethinking the Annual Compliance and Ethics Flea Dip ", author James Nortz discusses the annual compliance and ethics training program that most US company's employees receive which he calls a ' flea dip' . While...
  • Blog Post: Don’t Fold ‘Em: Making the Case for Ethical Leadership

    In an article published in the June issue of ACC Docket, entitled " Playing the Cards You're Dealt ", James Nortz raised the interesting issue of the lack of company leadership to "create an ethical vision, the moral courage to pursue that vision and the ability to effectively ...
  • Blog Post: How to Engage Employees in Compliance

    In the September 2011 issue of the Harvard Business Review , in an article entitled " How to Cultivate Engaged Employees " , author Charalambos A. Vlachoutsicos wrote about his experiences in working for a family-owned multi-national organization. From his experiences he learned how to...
  • Blog Post: Utilizing the Corporate Secretary in your Ethics and Compliance Efforts

    How can a Corporate Secretary enhance a company's overall ethics and compliance efforts? Corporate Secretary Deputy Editor Aarti Maharaj recently explored these issues and others in an interview with Matt Lepore, Vice President and Chief Council for Corporate Assistant General Counsel at Pfizer...
  • Blog Post: Jeannette Rankin, Infosys, Ethics and Compliance

    Who was Jeannette Rankin and why do we celebrate her today in the context of ethics and compliance? She was the first female to be elected to Congress, as a Representative from Montana in the 1916 elections. In 1917 she was one of 50 votes opposing America's entrance into World War I. She had...
  • Blog Post: How Charles Ponzi Can Inform Your Compliance Program

    Yesterday, I used some of the wisdom from current CIA Director General David Petraeus to suggest how senior management might move forward with a compliance program. Today I will use a very different individual to help inform your third party due diligence, Charles Ponzi. My colleague Tracy Coenen...
  • Blog Post: Chesapeake Lighthouses and Lighting the Way for Compliance

    In the winter 2013 issue of the Colonial Williamsburg magazine is an article by Michael Lombardi, entitled " Lighthouses Marked the Shoals of the Commerce Clause ". In this article, Lombardi wrote about four lighthouses authorized by Congress in the late 18 th and early 19 th century to...
  • Blog Post: The Convergence of Bear Bryant and Johnny Football – Lessons In Compliance

    Sedona Arizona is known for its four vortexes, some of those alleged places where the universe has holes in it or overlaps (I can’t remember which). I have been to Sedona but I have never experienced such convergence (or the voids for that matter). However, in other ways the universe does seem...
  • Blog Post: Naval Theorists and the Measurement of Compliance

    If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great battle concept. If you are Corbettian, you probably think about a series of smaller...
  • Blog Post: The Abbey Grange, the Quality of Justice and Codes of Conduct

    In honor of the return of Sherlock Holmes to PBS with Season 3, I begin a week of Sherlockian themed posts. Today we consider the quality of justice that Holmes discussed in The Abbey Grange , he allowed a man who murdered a wife-abusing husband to go free. Holmes concern with justice, as opposed to...