During the past month, I've been in London at the SCCE European initiative conference and last week at the Florida convention of the Health Care Compliance Association. The month has been an opportunity to gain some new perspective on the community of global compliance officers.
Entries in Caremark (6)
Official expectations that companies will check to make sure that their compliance and ethics (“C&E”) standards are being followed have existed since the advent of the Federal Sentencing Guidelines for Organizations in 1991. Additionally, only a year later, a U.S. Department of Justice official emphasized the importance of auditing to antitrust compliance, which underscored that checking was expected not only regarding the overall compliance program (e.g., training, the hotline) but also substantive areas of risk. However, while checking expectations have been present from the beginning of the “Age of Compliance,” for many reasons they are more significant now than ever before.
The SCCE Compliance & Ethics Institute could become the focus for an annual debate within the compliance field about the critical issues ahead. In honor of the SCCE’s 10 years of supporting compliance officers, here are my top ten suggestions for next year’s SCCE agenda:
At oral argument Thursday in the Delaware Supreme Court, where Walmart is appealing a lower court order to produce internal FCPA investigation files to shareholders, one remarkable exchange indicated that the idea of revising the Caremark standards, which I talked about in my prior post, was squarely on the minds of the justices.
Parental controls: Anti-corruption compliance programs for joint ventures, subsidiaries and franchisees (Part 2)
What's the first thing compliance officers need to do? We'd say it's convincing management and board members they need an effective compliance program. That's not easy. It takes advocacy, and advocacy takes credibility.