Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Richard L. Cassin Editor at Large

Elizabeth K. Spahn Editor Emeritus 

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor

FCPA Blog Daily News

Entries in Code of Conduct (8)


Warning: Flawed Codes of Conduct can create ethical complacency

In a recent post, I shared insights from a code-of-conduct best practice study I recently conducted in collaboration with SAI Global. As noted in that post, “companies …are not neglecting all the design elements needed for the code to successfully influence the organization’s ethical orientation and culture. But… they fail to go all the way..."

Click to read more ...


Do modern Codes of Conduct help cause and conceal unethical behavior?

How well positioned are today’s code-of-conduct practices to meet the effectiveness criteria for Corporate Compliance Programs embedded in the latest DOJ guidelines? That is, "Is the compliance program well designed? Is it being implemented effectively? And does it work in practice?”

Click to read more ...


Codes of Conduct: Are we honorable or are we hypocrites?

Yes, it should set out rules to follow. Here’s the company position about conflicts of interest. About giving and receiving gifts. About political contributions. And so on.

Click to read more ...


Feds continue Halliburton Angola, Iraq investigations

Here's the latest FCPA disclosure from oil field services firm Halliburton Company from its Form 10-K filed with the SEC on February 7:

Click to read more ...


Compliance officers can only succeed together

Michael Scher's post, The real code of conduct nobody mentions, brought this to mind.

Click to read more ...


The real code of conduct nobody mentions

We've been talking about codes of conduct for compliance officers. But let's face it. At too many companies, the true code is simple: Please Your Boss. The conflict resolution principle is Go Along to Get Along. In practice, at these companies compliance is subservient to the power and prerogatives of top management.

Click to read more ...


What codes of conduct can (and can't) do

The discussion of a Code for Compliance Officers highlights some of the strengths and weaknesses of the compliance profession.

Click to read more ...


‘The majority of compliance officers wouldn't take such risks’

A compliance professional working in China posed this question: What is the role of a compliance professional?

Click to read more ...