We are being bombarded by awesome games. This week, we brought two must-try adventures. The first, Somerville, is the spiritual sequel to indie mega-hits Limbo and Inside. The second is Dave the Diver, a game we hadn't heard about until scuba fishing/sushi serving/business management sim skyrocketed up the Steam Charts. The quirky cocktail is one of the most memorable roleplaying experiences in a long, long time. This episode's lineup may be the closest we've come to "you will find something to love, guaranteed." Hope y'all enjoy!
Our guest today is Hunter Thurman, President of Alpha-Diver. Alpha-Diver is a consultancy that leverages neuroscience to help brands target the right consumers and identifies the best moments for activation. Prior to starting Alpha-Diver, Hunter served as a Consultant for WPP in Global Insights, Strategy, and Innovation. Additionally, he served as an Innovation Strategy Mentor at The Brandery. Find Hunter Online: LinkedIn: https://www.linkedin.com/in/hunterthurman/ Alpha-Diver: https://www.alpha-diver.com/ Find Jamin Online: Email: email@example.com LinkedIn: www.linkedin.com/in/jaminbrazil Twitter: www.twitter.com/jaminbrazil Find Us Online: Twitter: www.twitter.com/happymrxp LinkedIn: www.linkedin.com/company/happymarketresearch Facebook: www.facebook.com/happymrxp Website: www.happymr.com Music: “Clap Along” by Auditionauti: https://audionautix.com This Episode is Sponsored by: This episode is brought to you by Michigan State's Marketing Research program. Are you looking for higher pay, to expand your professional network, and to achieve your full potential in the world of market research? Today, the program has tracks for both full-time students and working professionals. They also provide career support assisting students to win today's most sought-after jobs. In fact, over 80% of Michigan State's Marketing Research students have accepted job offers 6 months prior to graduating. The program has three formats: The first is a Full-Time 100% Online program taught over 12-months starting in January 2022 The second is a Part-Time 100% Online program that is 20-months. This one starts in May 2022 and is specifically designed for working professionals, And of course, they offer a Full-Time 12-month in-person experience that starts in September 2022 All programs include real-world experience and full-time job placement support. If you are looking to achieve your full potential, check out MSMU's programs at: broad.msu.edu/marketing It costs nothing to get more details. Take the time, invest in yourself. You are worth it and your future self will thank you. Class sizes are limited, so please, check it out today. This episode is brought to you by HubUX is a research operation platform for private panel management, qualitative automation including video audition questions, and surveys. For a limited time, user seats are free. If you'd like to learn more or create your own account, visit hubux.com. [00:00:00] Jamin Brazil: Hi everyone. You're listening to the Happy Market Research podcast. Our guest today is Hunter Thurman, President of Alpha-Diver. Alpha-Diver is a consultancy that leverages neuroscience to help brands target the right consumers and identify the best moments for activation. Prior to starting Alpha-Diver, Hunter served as a consultant at WPP and Global Insights of Strategy and Innovation. Additionally he served over a decade as an innovation strategy mentor at the Brandery. Hunter, welcome to the Happy Market Research podcast. [00:00:36] Hunter Thurman: Great, thank you. Great to be here. [00:00:41] Jamin Brazil: The Michigan State University's Master of Science in marketing research program delivers the number one ranked insights and analytics degree in three formats. Full time on campus, full time online and part time online. New for 2022. If you can't commit to their full degree program, simply begin with one of their three core certifications. Insights design or insights analysis. In addition to the certification all the courses you complete will build towards your graduation. If you're looking to achieve your full potential check out MSNU's program at B-R-O-A-D. M-S-U. edu/marketing. Again, B-R-O-A-D. M-S-U. edu/marketing. WX is a research operations platform for private panel management, qualitative automation including video audition questions and surveys.
When you think of missing person cases, you might imagine groups of volunteers scouring fields or search dogs sifting through a forest or even faces on milk cartons from a past life. But not all disappearances are landlocked. Some crimes are buried deep beneath cold water, which is why it takes a specially trained individual to search depths where no one else can or will go. To tell the unique story of these professional divers is none other than Bobby Chacon – former FBI Special Agent, as well as the man who helped create the FBI Dive Team. Bobby is here to uncover what really happens to bodies underwater and during a plane crash like the infamous TWA Flight 800 when an airplane full of 230 passengers completely snapped in half mid-air after leaving JFK. Plus, he shares his experience of leading the dives for both Laci Peterson and Samantha Koenig – the last victim of serial killer Israel Keyes. AND we dig into the Body Farm in Knoxville, Tennessee and the Chris Watts case, before ending on whether or not the wrong people are currently running the FBI.Learn more about Bobby Chacon's story HERE!Get TWO free black angus new york strip steaks by visiting GoodRanchers.com/CLARK or using code CLARK. Good Ranchers: American Meat Delivered.Are you ready for the BIGGEST, BADDEST, CONSERVATIVE party of the year?! Register for AmericaFest TODAY and use code POPLITICS for 25% off general admission. We can't wait to see you there!
How do you follow up a certified club banger like 2018's God of War? Join us as we discuss Sony Santa Monica's daunting sequel and its unsurprising breakout star. (Spoiler: It's Richard Schiff.) Also discussed: Signalis, Dave the Diver, Marvel Snap, Binding of Isaac
Game Store Owner CCgamesCEO joins us to talk about God of War Ragnarok, Sonic Frontiers, Call of Duty Modern Warfare II skins on eBay, Dave the Diver, Spellbook DemonSlayers vs Soulstone Survivors vs Vampire Survivors, The Past Within co-op, Gotham Knights, Harvestella, Bayonetta 3, Top selling Switch games, Nintendo mobile, PS5 Slim, and is Sony dead? Come to our Discord on https://discord.gg/Ab6pxpT to support us and get perks, win John's Rub, and get a pin, or go premium for weekly bonus shows and the back catalog of VGO on VideoGameOutsiders.com
Joe Cadwell works as an apprentice coordinator for the Pacific Northwest Carpenters Institute in Portland Oregon. After working 20+ years as a commercial diver for the Carpenters Union, Joe began a new career in 2019 as an apprentice coordinator and instructor for the Pacific Northwest Carpenters Institute, based in Portland, Oregon. His understanding and appreciation for those who do the hard, dirty and sometimes dangerous work of construction is apparent in his bi-monthly podcast. Joe created Grit Nation to shine a positive light on the many misconceptions surrounding careers in the blue-collar trades. Every episode is built to redefine what it means to possess skills that can't be outsourced or rendered obsolete overnight. Skills that provide a pathway to professional and financial success all while building the infrastructure and generational wealth of our nations. Through inciteful and probing conversations with building trades professionals, authors, and industry leaders, Joe digs deep to uncover the truth about the often misunderstood and under-appreciated blue-collar trades and the people who do them. "Podcasting has allowed me to meet an amazing cross section of an industry that I am proud to be part of". Joe Cadwell Links https://www.linkedin.com/in/joecadwell/ https://www.pnci.org/ https://www.gritnationpodcast.com/ ABOUT PODCAST Skill Stadium podcast is the voice of the skilled trades. Every Tuesday morning, we feature guests from all over the world with the following backgrounds: Business Owners Hiring Managers Skilled Trades Professionals Trade School Administrators Career Coaches Skilled Trades Influencers The purpose of the podcast is to share stories, career advice, and job opportunities in the skilled trades. You are invited every week to listen in on a conversation with people who are passionate about the skilled trades. You get the information you cannot google, from real people doing the work. Skill Stadium Links Website www.skillstadium.com Apple https://podcasts.apple.com/nz/podcast/skill-stadium/id1530074050 Facebook https://www.facebook.com/SkillStadium4Jobs Instagram www.instagram.com/skillstadium/ YouTube Channel https://www.youtube.com/c/SkillStadium LinkedIn https://www.linkedin.com/company/skillstadium/?viewAsMember=true Twitter https://twitter.com/SkillStadium TikTok www.tiktok.com/@skillstadiumtradesjobs
262: Sinead Diver | New York City Marathon | Alex Bell This Episode is proudly brought to you by lululemon. Athleisure brand lululemon and Movember, proudly unite for the third year of their partnership, to improve men's wellbeing through movement, mindfulness and connection. Check out the lululemon x Movember Capsule collection at lululemon.com.au Sinead Diver returns to the show and talks about the year that's been as she builds up to Valencia Marathon Brady returns to briefly check in from the Road To Valencia and shares some workouts he's got lined up. Brad's got some issue with elevation readings on his watch and his local fun run. Jess Stenson placed 9th in the New York City Marathon in 2:27:27, while Eloise Wellings ran 2:34:50 for her 5th marathon in 13 months. Evans Chebet won in 2:08:41, adding to the Boston crown after Brazilian Daniel Do Nascimento held a commanding lead splitting half in 61 minutes before being dramatically withdrawn at 34km, while Sharon Lokedi won on debut in 2:23:23 with Hellen Obiri also making her debut to place 5th in 2:25:49. Official NYC Marathon Results https://www.runnerstribe.com/latest-news/jessica-stenson-finishes-9th-in-new-york-as-the-top-3-run-sub-224/ Queensland 5000m Championships won by Callum Davies and Brielle Erbacher. Queensland Athletics Results Canberra Times Fun Run 10K won by Paige Campbell ahead of Marnie Ponton, Michael Chapman with winning the men's race. Rachel Waters and Ben Maccronan won the half marathon. Results World Mountain & Trail Running Champs Chiang Mai Thailand, held Long Trail 80km, Short Trail 40km, Uphill Mountain Race and the Up & Downhill Mountain Race. Notable Australians included Elena Stephenson 29th in the Uphill Mountain Race, Paige Linegar 29th in the Short Trail Race and Zack Newsham 29th in the Junior Up & Downhill Mountain Race. Official World Mountain & Trail Running Results Lululemon Ambassador and physiotherapist at The Running Room, Alex Bell joins the show to talk about More Than A Run, which invites running crews from across Australia to come together for this mental health initiative by taking on a distance of their choosing. Alex talks about being the physio for Nedd Brockman for his run from Cottesloe Beach to Bondi Beach and the significance of More Than A Run. https://www.instagram.com/p/CkpB8o4PUvi/?hl=en Listener Question doubles as the return for Training Talk asks how to go about pacing reps for a workout then Brady goes Loose on Athletics Victoria charging money for spectators to watch the Victorian 5000m Championships. Patreon Link: https://www.patreon.com/insiderunningpodcast Opening and Closing Music is Undercover of my Skin by Benny Walker. www.bennywalkermusic.com For shoes or running apparel contact Julian at: https://www.facebook.com/therunningcompanyballarat/ Join the conversation at: https://www.facebook.com/insiderunningpodcast/ To donate and show your support for the show: https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=9K9WQCZNA2KAN
Welcome to the Scottish Watches Podcast – Episode 411! Are you feeling as adventurous as Rolex felt when announcing the new RLX Titanium Deep Sea? If not then maybe the... The post Scottish Watches Podcast #411 : Going On A Deep Diver With The New Rolex Plus Other Watch News appeared first on Scottish Watches.
We return with a guest this week! Shroud joins us to catch up with his time away from Twitch and his current outlook on streaming as a career path. Then we get technical with PC hardware and player performance in games, how we tackle burn out and more! In the second half we finally chat about Gotham Knights, check in with the state of Overwatch 2 and FPS games in general then move in to some Kojima as well as Dave the Diver and a cheeky look at mobile shooter GODDESS OF VICTORY: NIKKE!
In September, the Department of Justice Fraud Section announced a new policy direction on corporate misconduct, clearly stating that personal accountability for employees, executives, and directors was their number one priority. The revised DOJ policy clearly states that an organization's compensation and benefits program must be aligned to its values and ethical culture. So, what does this mean for compliance? In this episode of the Principled Podcast, host Susan Divers discusses how to implement a meaningful performance management system that meets DOJ objectives with Stephanie Ragan, a Certified Compliance and Ethics Professional (recently of SOFEC) and now solo practitioner after 14 years as a compliance specialist and manager in the oil and gas industry. Featured guest: Stephanie Ragan As an experienced, well-rounded compliance and ethics specialist, Stephanie has recently struck out on her own by launching Ragan Export Compliance, a consulting company focused on providing services and guidance for regulatory compliance. A subject matter expert in trade compliance for the past 10 years, she holds both a Masters of Science in Regulatory Trade Compliance and a degree in International Trade Management. Her credentials include special certifications as a Certified United States Export Compliance Officer (CUSECO), a Certified Compliance & Ethics Professional (CCEP) and an FCPA Expert (FCPA Blog).With a passion for developing efficient, integrated and automated compliance systems and programs, Stephanie's philosophy is that the intentional integration of compliance and ethics elements within an organization is at the core of every successful business model; and through making compliance accessible and approachable to all stakeholders, the value of a company's culture is significantly increased. Featured host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years' accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM's Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM's ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers' thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company's ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative. Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: Last September, the Department of Justice Fraud Section announced a new policy direction on corporate misconduct. And they clearly stated that personal accountability for employees, executives, and directors was the department's number one priority. And as part of that, the revised policy that DAG, Lisa Monaco put out that day makes clear that an organization's compensation and benefits program must be aligned to its values and ethical culture. That means that positive behavior, for example, turning down a tainted business opportunity should be an essential factor in evaluating performance. And that there should be financial penalties, real financial penalties for misconduct. So what does that mean for compliance professionals? Hello, and welcome to another episode of LRN's DAG, Lisa Monaco. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. Today I'm joined by Stephanie Ragan, a certified compliance and ethics professional, and most recently of Sofec, an oil and gas provider that's global in its operations. Stephanie has just left Sofec and is now consulting on her own after 14 years of a compliance specialist and a manager in the oil and gas industry. We're going to be talking about implementing a meaningful performance management system that meets DOJ objectives and how you go about that. Stephanie, thanks for joining me on Principled Podcast. Stephanie Ragan: Thanks for having me, Susan. Susan Divers: It's my pleasure. Interestingly, one of the questions we ask in LRN's annual program effectiveness survey is about organizations using ethical behavior as a significant factor in compensation, bonuses, hiring and promotion. And last year 69% of the over, I think it was about 1200 ENC programs that we surveyed, indicated that they required that an employee's ethical behavior be evaluated as part of their annual performance review. And we found that top rated programs were much more likely with 88% including such criteria. But Stephanie, as you know, with all things compliance, the devil is in the details. So I'd really like to hear about how you implemented your program that does just that at Sofec. And I'm sure our listeners would love to profit from your experience and your wisdom on this subject. So let's start at the beginning, how did you start this initiative or how did it start and how did you get support for it? Stephanie Ragan: Well, sure. So coming from a company like Sofec, we just celebrated our 50th year and we have a lot of mature programs and some that are still coming along. And our compliance program was one of our newer initiatives. We started it in about 2011. And it was interesting to see that when we formalized that department and all of our programs, policies, everything that helped sustain it, there was a need to measure it against other overhead type departments like HR, HSE and quality. So looking toward those types of departments for direction to see how we could measure effectiveness of programs and tie that back to our professional performance goal setting efforts that we do on an annual basis was a challenge for us. And we decided that as the new kid on the block, we could look at what worked for everybody and what didn't. And we decided that it would be necessary to look at what weight we needed to hold within the organization for each of our compliance initiatives. So for a starting point for our listeners, I would suggest that you look at the way your organizations measure performance. And if there is already an existing HSSEQ component or HR component, that you should also be including a compliance and ethics representation. And that should be a key area of focus for your personnel to align with your company culture and your company code and business operations. Susan Divers: That makes a great deal of sense. And I want to pick up on one thing you said in particular, which is that the ENC program needs to have equal status and weight with other similar programs, whether it's HR or audit or security or health and safety. And that's actually in the 2020 guidance from the Department of Justice as well. Because one of the questions prosecutors will ask or are told to ask companies accused of misconduct is, "Does your ENC program have equal status and resources?" So the approach you took fits very nicely with that. Let's talk about how you actually went about it. How did you enlist support? How long did it take? And what did you do in the end to get it up and running? Stephanie Ragan: Well, you know it takes a village to have any kind of success. And our compliance and ethics global team really took on this call to bring compliance and ethics to the forefront, it having an equal say in the performance measurements that we do in the company. And we were able to within the last few years, convince our management that along with performance measurement, which was a key area of concern, we needed to have regular meetings, at least an annual meeting, to be able to confer as a team globally and to discuss ideas, work on program development and get training initiatives ironed out. Kind of plan out our year as a whole so that globally we could have a cohesive plan that aligned everyone, didn't leave anyone behind from a planning standpoint for all of our entities, and made sure all personnel were covered by local compliance and ethics designees that could administrate and cover those programs as we rolled them out. So this was very well taken on. And again, we leaned back into HR and HSE were having these types of annual meetings and conferences internally in the company. So we wanted to say, again, we need to make sure compliance and ethics is represented. It was well received and management was very supportive. So in 2019, we had our first global gathering. And at that point, we all discussed how we measured and where we had gaps in measuring those compliance and ethics performance areas. And we figured that the global initiative of tying it into your bonus, your compensation that's measured annually by HR, that we needed to partner with them as well. So we were able to utilize the great guidelines that were out by the Department of Justice that came out in 2018, 2020. And then similarly, we had more guidelines come out again this September. These types of guidelines were helpful in getting the highest levels of buy-in. So using that as leverage, we were able to place value on measuring those individual participation to show evidence of a effective compliance program. And we were able to also work with legal. And I think that that's something that anyone who's struggling with finding a way to tie their individual performance metrics for users to compliance and ethics, that having your legal team work with you, if that's not already part of your compliance and ethics team and working with HR to jointly explain to senior management why the Department of Justice guidelines are so helpful and necessary to pay attention to. No one wants to have those types of individual penalties pointed back toward them. And letting them know what the enforcement and penalty details could entail, it can be a little scary and overwhelming for them, but it lets them know the weight of importance. So moving on, our CNE team wanted to then, after we had our senior buy-in, determine specific ways to quantify a compliance and ethics participation that was acceptable. So we developed a way to be able to measure and do a cumulative total for each employee throughout the year. And with the help and guidance of our compliance council, our general compliance council, which oversees all of our compliance and ethics initiatives from a senior level, and our chief compliance officer who's over our entire group, performance matrix was developed. So we determined what KPIs and metrics were most valuable to our company and also how participating in training and completing mandatory training assigned on time or early would be a key indicator that our personnel were engaged in in meeting their CNE goals. Now that was our initial concern that the training and focusing on training, on time training completion wouldn't be enough, but that's a great baseline. So if you are not measuring that, start there. And we also decided though that's a minimum expectation, that other avenues of participation engagement could then be easily added. This was a chance also for our CNE team to promote all of the tools and the outreach that we had been developing to engage individuals in our annual Compliance Week program, our local newsletters, which we could insert quizzes and different activities for them to complete, optional live and virtual training sessions, surveys, quizzes, and use of compliance videos and slides in their operational meetings and team meetings. And then it gave us an opportunity also for people that really went above and beyond to be recognized and have that tied back into their performance goals as a metric to, so our compliance champions who always went above and beyond, or personnel who brought forward potential compliance and ethics issues that were helping make formative changes to our program could also be recognized. That sounds like a lot to keep track of and could be really overwhelming for our listeners that have a new compliance program, limited resources, budget constraints, but there are a lot of great tools and support out there like LRN that is a great content provider and provides support with measuring that on time participation and a lot of other value that you can add into your program. Let's face it, at a minimum, any functioning compliance program is at least checking the box with mandatory compliance and ethics training like anti-corruption or your company code training, general CNE program awareness. So if you start with training as your first building block to measurement, it'll be less of a shock and easily accepted because your population and your personnel are already participating in those training initiatives. Susan Divers: That's a great story. And the way that you worked with other people in the company to identify where you were going to start with the criteria I think is very powerful for people who are grappling with this subject. And I know it's not just companies that are new or small, it's an area that I think a lot of people are still trying to chart their way. And also using the Department of Justice guidance strategically to help management understand why this is a risk that really needs to be managed. I think there is emphasis when you look at the guidance, it's important to realize that it's out there in part to help people like you and your team actually implement it by putting it under an official seal, if you will. So well done. Hey, tell us now, how is it working and are there any tweaks that you would make at this stage? Stephanie Ragan: Well, the great news is we've certainly seen improvement. So we've seen results of greater participation across the board in all of our areas. So whether it's people participating in Compliance Week because they know it ties back to their performance or they attend training that they would've otherwise blown off or not considered taking because it wasn't mandatory. And that is really energizing us to continue to grow the program and continue to find ways to reach people. And we've seen a lot of participation because of this initiative of tying it to performance goals in areas and regions where maybe culturally it wasn't important before to participate in compliance and ethics initiatives. But now they understand because they have something that's tangible material that ties back to their actual individual performance and they want to succeed in that area. So in general, it's helped us create different types of communications. We've been able to go and create management reports to provide managers live specific data on how each of their team members are performing throughout the year. Some managers reach out for that quarterly or semi-annually, but everyone reaches out for it toward the end of the year when they're wrapping up their performance evaluations. And it's great to have that kind of tool. So I do recommend that you work on creating something as simple as an Excel spreadsheet that can start capturing data to keep good records regarding the performance of your personnel. And also, if ever you are audited by a government authority, it's a great tool to provide your training records and say, "We're not just checking the box, we are going above and beyond by tracking every engagement with compliance and ethics." So also following that, we're able to use those participation records to quantify a score for each person. Now, it doesn't necessarily have to be a numeric score. Some companies may want to do it that way. We aligned with what our HR teams were already using, which is kind of a scale one to five, either unsatisfactory and then failed to meet expectations. You either met expectations, exceeded expectations, or you did outstanding work. So because that was already in use in our system, it was a language everybody understood and we created what fell into each category for our measurements on the compliance and ethics side. And again, we don't have to reinvent the wheel, you can use what you have and work smarter, not harder. But tracking the progress is really important. So if you can assign something that you can put a value against, then you can develop statistics over time and track trends within the organization. We did have a lot of discussion across the board about how much weight should be given to compliance and ethics performance compared to HSE or HR. So again, we fought to have equal footing because we preach in our company code of, we have a culture of compliance, we have our compliance code that gives guidelines on how to operate in every aspect and provides best business practices for everyone. So there was no reason to sell ourselves short or give ourselves a discount and say, "We don't want to be considered equally." Even though some companies may need to tweak that based on what their own business practices are, it should have some alignment with your culture and your code. And that way people understand it and can buy into it on an individual basis and an organizational basis. So looking forward in 2023, and this is largely in response to the new DOJ guidelines that you mentioned earlier, which came out September 15th, that does focus a lot on enforcement. So again, we have that leverage to push and say, "This is important. You don't want to be in trouble because this is how it can affect you as an individual." And that does garner a lot of attention and response from senior management, which is great. We don't want to scare anyone, but we want to make sure they understand the weight of their actions or inactions. But our tweaks moving forward would include tiered measurements, and that aligns with the Department of Justice newest guidelines so that you have different measurements and expectations for managers and supervisors and executives. And I think you should really look at that as three different categories, general personnel, people who have an influence over them, managers and supervisors, and then the people at the top. So your executives are going to be viewed differently if enforcement actions are ever taken. So you might as well prepare and have your program mirror that type of focus internally. We also have a lot of questions that come up then from managers that say, "What are my roles? What do I need to do to earn my points or to get a good rating?" And we always encourage them to infuse and integrate compliance and ethics into their team talks, their safety minutes that they have at a beginning of a meeting, replace some of those with compliance moments. And we make those tools available easily so that they can download it from our [inaudible 00:19:23] and they have full access to short videos, to content that we can pull from different training providers or that we've developed internally. That just makes it easier if they have one stop shopping, they can go to your compliance site. And if you don't have that type of setup, don't worry. Companies can always make it available by emailing that out to managers and just having kind of the library available to them. And as you develop and tweak your offerings, let people know. It's good to self-advertise within the organization so that send an email out to all of your managers and say, "Hey, we have a new video available if you want to share it with your teams." And let those managers come back to you and let you know how they used them and what the feedback is, because that's just going to help build the program and continue your process improvement. As the DOJ recommendations indicate, effective compliance program always points to individual emphasis for that compliance and ethics participation and compensation. And I think we can agree that those personnel who embrace and make an effort to incorporate compliance and ethics into their work are more likely to report potential issues, be less likely to become bad actors by breaking rules intentionally or unintentionally. And generally, they're going to support the best practices and the compliance and ethics program in the organization. Susan Divers: Well, we would certainly agree with that. And our research at LRN shows overwhelmingly over the years that I've been here, which are now six, that a culture of compliance that involves employees at as many levels as possible and helps them by giving them materials, you mentioned making it easy for managers to talk about ENC, that that is the best defense to misconduct and it's not how many times you reinvent in your code of conduct. But I do want to mention one other thing that you talked about early on, which is data points and having something that shows exactly where a particular individual is in their ENC journey, whether it's training or touchpoints. We've actually just redone major parts of our platform and we're very excited about it because there's a part that we're rolling out this month called Reveal, which is advanced data metrics from the training experience. And it shows what courses, what subjects people struggle with the most, how much time employees spend on a given subject and a lot of other very relevant data. It's very powerful and it allows you to benchmark against yourself and against other companies in your area. That's something everybody is very focused on. And using that in conjunction with your performance review system can really drive change. And then I'd also mention managing that data is important. We also are including a tool that we've had for some time called Disclosures where we're asking people to tell us when they attest to the code of conduct or when they roll out. You can use it to track how many times they roll out an ethical moment or other times when they talk about ethics and compliance. So the idea is to make it as easy as possible for the compliance team to track that. But we're starting to run out of time, so I want to talk quickly about what are the pitfalls. Because obviously this is a terrific program that has gained traction and is broadening and improving as you go along. But what are the pitfalls to avoid? And then I want to talk about your new company and your new initiative too. Stephanie Ragan: Well, first of all, the biggest pitfall that you can have is to not do anything or to be stymied and overwhelmed. So don't overthink or over design any initial measuring system. Remember that look to the offerings and tools that are made available to your personnel already. So start with finding the easiest way to measure what you're already doing. And you can always scale up as part of your continuous process improvement efforts. And then again, as you saw for development of our program, we could not have done this if we had worked in a silo. You have to engage and partner with HR and other stakeholders in the organization to find a way to infuse that measurement of your ethics and compliance participation. And be sure to include that there is a way to acknowledge excellent contributors. Because that drives people and excites them to participate more. So it can be an incentive for good behavior and make it specific to a task or event that's not evergreen. You can change this around and continue to improve it as years go on and set goals for your compliance and ethics team to be able to continue to develop every year something different to bring more users on board. Susan Divers: That makes a great deal of sense. And again, congratulations. That's a major accomplishment. And it sounds like the program was very well designed for your business and your particular culture and your risks. So let's turn to the future now with your own business, Ragan Export Compliance. What kinds of clients will you be aiding in the development of their ENC programs? I know you have deep experience in the oil and gas industry and are a certified FCPA expert and have the export control function as well. What are you going be focusing on and what risks do you see developing for exporters in particular as they seek to adhere to the DOJ guidance? Stephanie Ragan: Well, thank you for asking about that, Susan. At Ragan Export Compliance, I'll be providing trade compliance support and guidance focused on export or import compliance plans. And large focus now is technology. So we'll be helping develop technology control plans. And also because I do have a background coming from the last five years of doing the certified compliance and ethics professional from SCCE, I also can help develop the corporate compliance program enhancements for any industry, which can include developing training programs, conducting training, auditing, risk manages, strategies, due diligence and screening ,vendor management systems. And if a system needs overhaul, that's something that people sometimes forget. They develop a compliance program and then put it on the shelf, but it really does need continuous review, especially in the light of recent and constant regulatory changes and updates. To get back to your question about what risks do I see developing from an export angle, I do see two areas where exporters can pay additional attention, especially considering the current international policies and issues that are going on in the world. The enhanced due diligence is needed now as part of your program to identify military end users or MEUs. And this is primarily in China, Russia, Venezuela, and Burma. But it's a good habit to get into looking at that and incorporating, identifying military end users and uses as part of your, know your customer and screening system for your full supply chain. And then the second area where there can be some additional attention paid would be that your program includes a really strong level of control for not just your physical shipments, but technology. That's a blindside for a lot of exporters, importers, and just USPPIs in general because they don't realize how wide the definition for technology is when you look at the regulations. So for example, the EAR definition of technology for Department of Commerce for controlled technology is any specific information that relates to development, use or production of controlled items, those technologies would also be controlled. So pretty much any information that relates to those items, because the development use or production is so broad. And the ownness of that comes back to the exporter. Whenever regulations are vague, it puts more pressure on the exporter to understand and have systems in place to be able to address potential violations. And then because of regulatory changes, a lot of stagnant compliance programs can be a real risk for companies because they may not realize it's something that they have always been able to export. For example, certain valves or stainless steel items, things that were pretty innocuous for a large part, didn't need licenses up until recently when regulations changed. And now they fall into this large basket categories like 2B999 ECCN numbers, which I know might sound scary and very technical to people listening that don't have a real firm grasp on the ECCN, but there's a lot of guidance out there, and that's what we hope to provide and be able to help navigate at Ragan Export Compliance. So finally, just in general, I would say that my advice to our listeners today is just to continually evaluate your compliance program and make sure that your CNE engagement measurement that we've discussed today become truly effective ways to ensure that your organization is on the path to executing best practices and avoiding any regulatory infractions. If you follow the guidelines and reach out for help when needed, you won't go wrong. Susan Divers: Well, thanks Stephanie. I certainly agree with everything you've said and want to emphasize your point about don't fall into the trap of stagnant compliance. A lot of times I think it's easy to rely on backward looking metrics and saying, "Well, last year we trained 340 people, and this year we hope to do more." It's important to really keep evaluating what are the new risks that we're facing, and are the procedures that we have in place adequate for those new risks? And certainly that's consistent with the guidance too. So unfortunately, we've run out of time, but I want to thank you very much for spending these minutes with us and giving us the benefit of your insights. I hope you'll come back and speak to us again soon. Maybe we can do a session on export control. And we wish you all the best in your new venture. Stephanie Ragan: Thank you, Susan. Susan Divers: My name is Susan Divers and I want to thank you all for tuning in to the Principled Podcast by LRN. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning, ethical cultures, rooted and sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.
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What you'll learn in this podcast episode Guidance from the US Department of Justice, particularly the recent 2020 memorandum, stresses that a company's compliance program must reflect and evolve with its risks—and should not be a snapshot or on cruise control. But in assessing those risks, it's helpful to see what other companies in the same area or circumstances have done to meet them. Collective action and coordination can be very useful in dealing with common risks. So, when is benchmarking and a collective approach to risk helpful? And when can it backfire? In this episode of the Principled Podcast, LRN Director of Advisory Services Emily Miner continues the conversation from Episode 6 about benchmarking with her colleague Susan Divers. Listen in as the two discuss the benefits and limitations of benchmarking, and how organizations can ensure they benchmark their E&C programs effectively. Featured guest: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years' accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM's Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM's ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers' thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company's ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative. Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Featured Host: Emily Miner Emily Miner is a director of LRN's Ethics & Compliance Advisory services. She counsels executive leadership teams on how to actively shape and manage their ethical culture through deep quantitative and qualitative understanding and engagement. A skilled facilitator, Emily emphasizes co-creative, bottom-up, and data-driven approaches to foster ethical behavior and inform program strategy. Emily has led engagements with organizations in the healthcare, technology, manufacturing, energy, professional services, and education industries. Emily co-leads LRN's ongoing flagship research on E&C program effectiveness and is a thought leader in the areas of organizational culture, leadership, and E&C program impact. Prior to joining LRN, Emily applied her behavioral science expertise in the environmental sustainability sector, working with non-profits and several New England municipalities; facilitated earth science research in academia; and contributed to drafting and advancing international climate policy goals. Emily has a Master of Public Administration in Environmental Science and Policy from Columbia University and graduated summa cum laude from the University of Florida with a degree in Anthropology. Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Emily Miner: Guidance from the US Department of Justice, particularly the recent 2020 memorandum, stresses that a company's compliance program must reflect and evolve with its risks and should not be a snapshot or on cruise control. But in assessing those risks, it's helpful to see what other companies in the same area or circumstances have done to meet them. Collective action and coordination can be very useful in dealing with common risks. So when is benchmarking and a collective approach to risk helpful, and when can it backfire? Hello, and welcome to another episode of LRN's Principled podcast. I'm your host, Emily Miner, director of Advisory Services at LRN. Today I'm continuing my conversation from episode six about benchmarking with my colleague Susan Divers, our director of Thought Leadership and Best practices. We're going to be talking about the benefits and the limitations of benchmarking and how organizations can ensure they benchmark their E&C programs effectively. Susan brings more than 30 years experience in both the legal and E&C spaces to this topic area with subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Susan, thanks for coming on the Principled podcast. Susan Divers: Oh, Emily, it's always nice to talk with you. Emily Miner: So Susan, before we get started, let's kind of define benchmarking and summarize the conversation that I had in our last podcast with our colleague Derek. So benchmarking means comparing what you do as an organization in this case to a usually large number of comparable organizations or individuals. And most often, this is done in a quantitative way, although there are also opportunities to benchmark qualitatively. And at LRN, we've been using benchmarks for a number of years now through our research reports. We've conducted major panel research on the role of ethical culture in an organization and in organization's risk of misconduct. So looking at how that varies across countries, across industries. We conduct every year research into ethics and compliance program effectiveness research that you lead and that you and I collaborate on. And we've been doing that for, oh gosh, coming up on, I don't know, maybe eight years now. That's been given us a insightful look into Ethics & Compliance Program best practices, and how they've evolved over time. We've also conducted research on codes of conduct, analyzing nearly 150 publicly listed codes of conduct from the top listed companies around the world and looking at similarities and differences and best practices in that space. But we have a brand new product at LRN that we're launching later this month that I know we're all really excited about called Catalyst Reveal, which is a platform that will, as it's name suggests, reveal insights to our clients about their ethics and compliance program, things like course level data training, data, employee sentiment, ethical culture. It will also give our clients the ability to see how their results along these metrics compare with other organizations in the LRN client universe. So looking at by industry, by company size, and a few other comparable filters. So with that exciting launch as our backdrop, I wanted to talk to you as an expert and a thought leader in this space about benchmarking compliance programs, when to do it, when not to do it, et cetera. So let me turn it over to you, Susan, and let's start with the benefits. What are the benefits of benchmarking in ethics and compliance program? Susan Divers: Sure, Emily, I'd be happy to talk about that. In thinking about this topic, there are really three really good functions that benchmarking is appropriate for. And then there are some where it's not so appropriate and we can talk about all of that. But starting with what it's very appropriate for, the first is if you're setting up a program, you need to figure out kind of what are the basics that you need to do at the outset. And it can be very helpful particularly if it's a new program, and it usually is if it's setting it up to be able to say your management, "We have to have a code. We have to have policies. We have to have audit. And we have to have training" and those are kind of the four basic pillars and being able to make that case. That's very basic, but it can be very helpful in terms of people who are struggling to get started in what we all know is a really complicated area. So that's kind of the first setting where benchmarking I think can be very helpful. And then the second is you've got your program and you're up and going. Now, no two companies are alike, no two industries are alike, and I can get into that a little bit later, but it's helpful to know if you're mainstream or not. Like for example, our Ethical Pulse Culture check lets you sort of get an idea from a short questionnaire embedded in our platform in Reveal whether your culture is really out of whack or pretty much along the same lines as mainstream. And again, that's really helpful because it can show you an area where you're maybe excelling and it's good to take credit for that and scale it, or it can show you an area where you're deficient and it's good to know about that too. And then the last is, and this is where for example Ethisphere has done a lot of really good work, best practices. People are constantly innovating. I'm always amazed at how ethics and compliance programs are changing and getting better. And we can talk about that a little bit, and Reveal's going to be very helpful there. But benchmarking can give you ideas that can be very valuable for enhancing your program. So those are sort of the three big areas where I think benchmarking can be extremely helpful. Emily Miner: Yeah, thanks Susan. And on that last point that you shared, that's really resonating because if nothing else, benchmarking or surveying what other companies are doing out there with respect to ethics and compliance and different facets of that, it gives you as an ethics and compliance professional just an idea of what's possible. Maybe there's a new approach to communicating with your employees that you haven't thought of that might work for your organization. I'm at the SCCE's Compliance & Ethics Institute right now, and there was a session yesterday about one particular organization's sort of their evolution of their compliance program following some significant trust that was lost in the organization to senior leader misconduct. One of the things that they talked about was having employees around the globe put on skits that they turned into videos that dealt with ethics moments and how the actors, which were the employees of the organizations, would kind of get famous around the world for their skits. It was a very lighthearted way of communicating very serious topics that resonated for this particular organization. But a lot of people in the room were asking questions, "Oh, well, how could I put together a skit like that? Did you write the script or did the employees come up with it and this and that?" Just that it's a way of sharing ideas and fostering innovation across the industry that can be really exciting and powerful. Susan Divers: Yeah, that's a great example, but maybe it's time to talk a little bit about the limits of benchmarking too because that's a good illustration of the point that benchmarking's good for the three things we just talked about. Setting up, making sure that you're in the mainstream and not at either end, or maybe you want to be excelling and then getting ideas and best practices. What it's not good for is saying, "Hey, we met the criteria." And the reason is there isn't a criteria. In fact, there was a quote two days ago or so from the CEO of Advanced Micro Devices, and she said, I quote, "It's like running a different company every two years." So the point I'm trying to make here is that your program has to be based on your risks, and those risks can change dramatically, I mean, certainly in the semiconductor area, and that's what she was talking about. The risks have changed, they basically changed radically with all the changes with China and the export sanctions and the war in the Ukraine. So it's not enough to say, "Hey, I'm doing what everybody else is doing in that area." And secondly, the other big problem is comparing apples to apples. I picked three consumer companies to sort of illustrate this. One is Walmart, which obviously is a big consumer company. Another is PepsiCo, another is Mondelez. And if you look at all three, they all have really different risk profiles. They may be in the same area generally, but Walmart's much bigger than the other two. Walmart had a major scandal a number of years ago where they wound up paying, I think it was 137 million in 2019 because in order to get permits for their stores in Latin America, particularly Mexico, their lawyers were actually paying bribes. When you think about it, that should have been something that they were sensitive to on their risk profile and both training and auditing the local lawyers. Also, there was some lawyers on their teams internally. That was a risk and they failed to mitigate it. PepsiCo is bottling, and so do Mondelez has plants, but it's not quite the same level of regulatory intensity as setting up a store, hiring people, environmental health. So I use that example because I'm trying to pick an industry and say, "Well, if you compared yourself to one, you might miss some of the particular risks that you have." One of the also things to bear in mind, and you alluded to it when we started, is that DOJ has never recommended benchmarking in all of the guidance. In fact, they've said things that kind of contradict benchmarking if you were using it to say, "Hey, we met the norm." They've said, "You don't want to be on cruise control," and that's because things change. And they've also said, "You don't want to just take a snapshot of your program at a given time." And that's kind of what the CEO of Advanced Micro Devices was saying too. And that's because any time you're looking backwards rather than forwards, you could miss the iceberg that's looming up ahead and going to sink the Titanic. So at any rate, I think benchmarking can be very useful, but you have to use it for the right purposes and you have to bear in mind the limitations. Emily Miner: Right. Absolutely. It's never the be all end all. It's one data point that we should be collecting and looking at in some situations and not others. And in those situations, it's one of many that we should be considering when we're thinking about program effectiveness. Susan Divers: Yeah, it's an element. Yep, absolutely. Emily Miner: So let's kind of tease this out a little bit more. Where do you see benchmarking being helpful? I know that you gave those three scenarios, but maybe if you could pick out a concrete example to share against any of those three scenarios to illustrate how it can be helpful or when it can backfire. Susan Divers: Sure. Well, let's pick another consumer company, Anheuser-Busch. This is a great example because it illustrates how benchmarking can be used very effectively to drive a best practice. Anheuser-Busch had a very prominent CECO who has very recently left to go to the Department of Justice in the last couple of months. When he was there, he set up an internal data analytics program that was able to pull data from their own systems, payments, SAP of course, onboarding and pick out red flags without, if you will, human intervention. In other words, he was able to take a number of data streams from various parts of the company and meld them together. And because he was very good CECO, he was able to figure out what some of the risk signs were or the red flags. What it did is it enabled Anheuser to manage its third parties, which if you think about it, beer distribute, beer companies have a lot of third parties. And then they could focus in on those companies, those third parties where there were red flags. They didn't have to audit everybody to the same degree of intensity. And that approach of internal data analytics was a best practice that was gathering steam, sorry. But once Matt really took it to the next level and showed how it could be done, then it really became mainstream in the E&C area. And Matt's now at DOJ. So if you're going to go in and have tense talks with regulators, being able to talk about what you're doing in benchmarking is important. And it takes us back to Reveal where Reveal is a really powerful tool that we've developed that will enable you to see red flags or predictive factors. And again, remember looking backwards doesn't really help you because it doesn't tell you if there's a big iceberg about to sink the Titanic. But looking forward and saying, gosh, the data that's coming in from Asia on attempts to pass courses or on our Ethical Pulse Culture check or other features is worrying. It's nothing specific that we know about at this point, but it indicates that, I'm just picking on Asia randomly, it indicates that we need to spend some time in Asia figuring out what's going on. So that's really an excellent use of benchmarking and that's a good story as to how understanding what best practices are emerging and adapting them then for you, because nobody could simply take Matt's system of third party analytics and plug it into their company and come up with the same results. It has to be tailored and it has to be specific. But that's a really good example of what DOJ is talking about in this area where they say you have to tailor it to your risks. So does that make sense? Emily Miner: Yeah, absolutely. It's a great example with Anheuser-Busch and the system that they set up. I want to kind of talk about specific types of data that we collect in ethics and compliance or can collect, because I feel like the kind of two most common ones that organizations want to benchmark are training completion rates, that's a metric that is easy to collect and is often one that is shared, and hotline. "Oh, my hotline reports. How does this compare?" And the hotline providers will publish annual benchmarking reports on hotline. So we've got course completions, we've got hotline data, but we also collect other data points, or there are other places where we could to think about program effectiveness. I'd love to hear from you, as you think about the universe of ethics and compliance data, where do you think kind of benchmarking holds water and where does it not? Susan Divers: That's a great question, Emily, and I'm glad you asked it. Let's start with the hotline because that's a really good example in a lot of ways of two of the pitfalls. One of the major pitfalls that we touched on is are you comparing apples to apples or apples to potatoes? A company, let's take Starbucks for example, they have 300,000, relatively young, many of them first job employees. And are they going to call the hotline if they see something or worried about something? The odds are probably no even though they've got a big kind of young and engaged workforce because they're inexperienced. Most of their employees, I was talking to their CECO last week, and most of their employees really haven't worked extensively in the workplace. So Starbucks might have really low hotline numbers. Another company that's largely unionized, on the other hand, because unionized workers generally know about the hotline and they know about formal complaint processes, they'll have high hotline usage compared to other companies. Let's just pick a slightly ridiculous example, but a big manufacturer of clothing like the Gap or something. You'll have unionized workers in the plants, but Booz Allen is a consulting company. Are you going to compare hotlines between Booz Allen and the Gap? That really is an apples to potatoes comparison. So I think hotline benchmarking, and I know most of my colleagues in the E&C area would agree is very, very difficult because you'd have to really know what the workforces are to try to get an idea. And then secondly, it can be driven by other factors such as when I was at AECOM, we deployed a lot of people in the Middle East and the conditions were harsh. So our hotline complaints would go up when people were under stress, but another company might not have that circumstance. Emily Miner: Yeah, that's such a great point about when you're using benchmarking and you're considering using benchmarking, you have to be really thoughtful about what that benchmark pool is made up of. The union example is such a great one because even within the same industry, you compared the Gap to Booz Allen, but even within the manufacturing industry, for example, not all manufacturing company has a unionized workforce. So you can think, "Oh, well it's manufacturing, so it's comparable," but it might not be depending on the workforce dynamics. That level of insight isn't always available when we're benchmark data sources. Susan Divers: We forgot one thing that both of us know, which is I think the last stat I saw was more than 90% of meaningful issues are not raised through the hotline, they're raised in conversations with managers. So I've never been a fan of hotline benchmarking. Emily Miner: Yes, absolutely. Susan Divers: But to turn to training completions, that's an interesting one too. Again, it really depends. If you're using an old fashioned training provider whose library consists of 45 minute or even longer lectures, sort of Soviet style on the evils of sexual harassment, first, it's probably not very effective. And secondly, a lot of people won't complete a 45 minute course just because it's long. If the training is repetitive and hectoring, they'll drop out. Whereas the kinds of courses that we have and that we emphasize are very engaging, they tend to be shorter, they tend to be more microburst learning. So again, what are you comparing? Do you have a lot of employees on the shop floor? Well, it's hard for them. They can't really just take a break, sit down at their laptop and open up a course on antitrust. So again, I think training completions can be tricky. It doesn't mean it isn't interesting to see that data, but figuring out, again, whether you're making an apples to apples or an apples to potato comparison, I think is really important. And then secondly, remember, it's retrospective looking. It's not telling you anything about what's coming around the corner. Emily Miner: Mm-hmm. One thing that we've focused on in this discussion is comparing ourselves to other organizations. I mean, that was how I even defined benchmarking at the outset, but there's also internal benchmarking, comparing your own performance year over year or whatever the period of time is. When you were just talking about training completion, it made me think about that internal comparison, less so with training completion because I think it tends to be high, a lot of companies mandate it so there can be penalties for not completing training. So if it's high for that reason alone whether or not it's good or relevant to employees or they liked it or whatever. But thinking about metrics like pass/fail rates or number of attempts or test outs or some of those more nuanced training related data points and comparing against yourself year over year and seeing what has changed and what might be the result of that. I mean, maybe you noticed in year one that it was taking the majority of your employees or a significant minority of your employees more attempts than you wanted to answer certain questions correctly related to a certain risk topic. And so then as a result, you rolled out some focused communication and maybe you targeted specific groups of people where you noticed were particularly struggling for additional manager led conversations or whatever. And then in year two, does that pass rate or attempt rate improve? That's a helpful metric because you're comparing apples to apples, you're comparing yourself and you're able to connect it back directly to specific interventions that you may have need to make improvements in that area. So I just wanted to point out that benchmarking can be done internally as well. It's not always an external exercise even though that does tend to be how we talk about it. Susan Divers: Well, and you're exactly right, and that's where it gets really valuable because first you can make sure that you're comparing apples to apples. For example, if you've just done a merger and suddenly your population of employees has doubled, well obviously then you know that you've got a much different comparison year over year, but you can break that down and you can make those comparisons by manipulating the data. Secondly, your Ethical Culture pulse survey is a really good tool year over year adjusted for employee population size. And if we've got new people coming in the company, a merger for example. And it can be proactive. It can, again, spot trends as you were just saying that indicate that you may need to spend more time with people. But the beauty of internal benchmarking, particularly the way Reveal has set that up for our clients and made it easy is that you can get genuine insights looking at what happened last year, what happened this year and you know some of the reasons why there may have been a change. Whereas if you're comparing yourself to, I don't know, Ernst & Young, you don't. You don't have visibility in terms of their numbers. So internal benchmarking, I think you're right to stress that. And it's a very, very valuable tool. Emily Miner: I've done, as you know, a lot of work with organizations evaluating and assessing their ethical culture. The trend that I've noticed with those clients that we've done this type of work year over year over year is that the benchmark, the external benchmark just grows. It's important kind of in year one and maybe year two, but after that it ceases to be relevant and the companies don't really care what it is anymore because it's also they're not shooting for the benchmark. The benchmark is often the average and they want to be above average. And so it's more about competing with yourselves and how did we improve against our own performance last year? And so that's just been interesting to observe. I think as companies get more robust in their use of data and their tools and how it informs their strategy in some areas like ethical culture for example, that external comparison just becomes less relevant over time. Susan Divers: That's a really good point too. And that gets back to the Department of Justice saying, "Don't put your program on cruise control." And I do remember, I think it was 15 years ago when benchmarking was much more trendy and before people really thought through the limitations, someone was bragging that they had benchmarked their program against Boeing. Boeing then subsequently had major meltdowns left, right, and center most specifically and tragically the 737 MAX where people died. And so running around saying, "Hey, my program benchmarks well against Boeing" may not have been really a compliment to the program in the end. But it also misses the point which you're making, which is you have to look at your program and what's gaining traction with your people and where the proactive red flags are emerging because that's what enables you not to be Boeing, not to pick on Boeing, but it's a good example. Emily Miner: So Susan, let's wrap up by offering some recommendations to organizations that are thinking about program effectiveness, how they measure that. They want to have those benchmarks. Maybe they fall into those three scenarios that you outlined at the beginning. What recommendations or best practices would you offer to those organizations, to your peers? Susan Divers: Well, the first one is be really smart about it and avoid comparing apples to potatoes. And to do that, you have to really think it through. What are we comparing to whom and how similar are they? I really, again, think that's most useful for kind of like, "Are we in the mainstream? Or is there something maybe we forgot?" If it turns out that everybody in your industry has suddenly amended their training curriculum to train about trade controls in the wake of the Ukraine war and you haven't, well, that's a helpful benchmark. But I think the main ones that are valuable are what we were talking about with best practices and data analytics and the creative use of data analytics that are tailored to that particular company is a great example of that. And then the second one as you pointed out which I think is equally valuable and really essential too, is internal benchmarking up to a point where you're able to see what direction things are going in. And again, it's more in the nature of red flags rather than a way of saying, "Hey, we met the requirement, we're good." It's, "How are people doing this year compared to last? What does that tell me about where I need to focus my resources?" Emily Miner: Mm-hmm. Mm-hmm. Yeah, Susan, thank you so much. And thank you for joining me on this episode. We are out of time for today. So to everyone out there listening, thank you for listening to the Principled Podcast by LRN. It was a pleasure to talk with you, Susan. Susan Divers: Oh, it's always a pleasure to talk to you, Emily. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to you by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen and don't forget to leave us a review.
CONTENT Our guest today is Jim a former Royal Navy Clearance diver. On this episode we will cover the unit's history from inception in WW2, its current role, selection process, diving technology and operational deployments. DESERT ISLAND DITS On Desert Island Dits Jim's choice of film is Grosse Pointe Blank and his book is Death of a Hero: Captain Robert Nairac, GC and the Undercover War in Northern Ireland by John Parker. The teams book choice this week is The Last Dive: A Father and Son's Fatal Descent into the Ocean's Depths by Bernie Chowdhury and film choice The Silent Enemy SOCIAL MEDIA Check out or blog site on word press Unconventional Soldier Follow us on social media and don't forget to like, share and leave a review. Instagram @the_unconventional_soldier_pod. Facebook @lateo82. Twitter @TheUCS473. Download on other platforms via Link Tree. Email us: firstname.lastname@example.org. This episode brought to you in association with ISARR a veteran owned company.
Discover means to UNEXPECTEDLY find someone or something. Discovering yourself is like being a deep-sea diver. Divers have a process for learning how to discover what lies beneath the ocean waves. They start small, in a pool. They practice breathing a breathing pattern that helps them stay calm and remain longer under water. They move to shallow ocean depths and practice. They gain experience and build confidence. Then they can go deeper and travel farther to dive in new locations. They can do this all of their lives.It's the same for all of us and for kids. There is no end to what you can discover about yourself and the world. You can empower kids to create a process for self-discovery with breathing, body movement, and journaling tools. In our DISCOVER podcast, we'll practice 'divers breath' and journal about all the things you have discovered and hope to discover about YOU. www.kidssuperjournal.com.
What you'll learn in this podcast episode Over the last few years, federal regulators have provided detailed guidance on what they expect to see in E&C programs when it comes to misconduct inquiries or investigations. What do these recent reports, policies, and guidance mean for compliance professionals? In this episode of the Principled Podcast, LRN Director of Thought Leadership and Best Practices Susan Divers is joined by Jon Drimmer, a partner at the law firm Paul Hastings. Listen in as the two discuss the recent guidance from the US Department of Justice as well as DOJ policy impacting corporate compliance programs and ethical culture. Featured guest: Jon Drimmer Jonathan C. Drimmer is a partner in the Investigations and White Collar Defense practice and is based in the Washington, D.C. office of Paul Hastings. He resolves complex cross-border problems with the benefit of having sat in every chair at the table: senior legal officer for a global 500 company, federal prosecutor, and seasoned advocate. He is a recognized international expert on anticorruption and business and human rights, and is a frequent speaker, author, and commentator on issues related to both topics. Before joining Paul Hastings, he was Deputy General Counsel and Chief Compliance Officer of Barrick Gold, one of the world's largest mining companies, with operations on five continents. The compliance program he built at Barrick has served as an industry standard, and elements of it have largely been duplicated by numerous other companies inside and outside of the extractive sector. Mr. Drimmer has directed hundreds of investigations around the world related to anti-corruption, human rights, AML and export controls, tax controversies, environmental incidents, public disclosures, fatalities and health and safety injuries, sexual harassment and discrimination, and other areas. He has represented companies and individuals in numerous government enforcement proceedings in the U.S. and overseas, in relation to FCPA and bribery claims, human rights issues, and a wide array of other matters. He has participated in dozens of major disputes in the U.S., Canada, and abroad, including transnational torts, anti-corruption claims, environmental cases, international arbitrations, tax disputes, construction claims, and land controversies. He previously served in the Justice Department as Deputy Director of the Criminal Division's Office of Special Investigations, where he led cross-border investigations, first-chaired numerous prosecutions, and argued federal appeals. He was a partner at an Am Law 100 law firm in Washington, D.C., a former Bristow Fellow in the Office of the U.S. Solicitor General, and a judicial clerk on the U.S. Court of Appeals for the Ninth Circuit. Mr. Drimmer served on the board of directors of the Voluntary Principles on Security and Human Rights Initiative from 2012-2014, and again from 2015-2017. He served on the board of TRACE International from 2012 until 2018, and currently sits on the board of the TRACE Foundation. He has also taught international law courses at Georgetown University Law Center for nearly 20 years. Featured Host: Susan Divers Susan Divers is the director of thought leadership and best practices with LRN Corporation. She brings 30+ years' accomplishments and experience in the ethics and compliance arena to LRN clients and colleagues. This expertise includes building state-of-the-art compliance programs infused with values, designing user-friendly means of engaging and informing employees, fostering an embedded culture of compliance, and sharing substantial subject matter expertise in anti-corruption, export controls, sanctions, and other key areas of compliance. Prior to joining LRN, Mrs. Divers served as AECOM's Assistant General for Global Ethics & Compliance and Chief Ethics & Compliance Officer. Under her leadership, AECOM's ethics and compliance program garnered six external awards in recognition of its effectiveness and Mrs. Divers' thought leadership in the ethics field. In 2011, Mrs. Divers received the AECOM CEO Award of Excellence, which recognized her work in advancing the company's ethics and compliance program. Before joining AECOM, she worked at SAIC and Lockheed Martin in the international compliance area. Prior to that, she was a partner with the DC office of Sonnenschein, Nath & Rosenthal. She also spent four years in London and is qualified as a Solicitor to the High Court of England and Wales, practicing in the international arena with the law firms of Theodore Goddard & Co. and Herbert Smith & Co. She also served as an attorney in the Office of the Legal Advisor at the Department of State and was a member of the U.S. delegation to the UN working on the first anti-corruption multilateral treaty initiative. Mrs. Divers is a member of the DC Bar and a graduate of Trinity College, Washington D.C. and of the National Law Center of George Washington University. In 2011, 2012, 2013 and 2014 Ethisphere Magazine listed her as one the “Attorneys Who Matter” in the ethics & compliance area. She is a member of the Advisory Boards of the Rutgers University Center for Ethical Behavior and served as a member of the Board of Directors for the Institute for Practical Training from 2005-2008. She resides in Northern Virginia and is a frequent speaker, writer and commentator on ethics and compliance topics. Principled Podcast Transcript Intro: Welcome to the Principled Podcast, brought to you by LRN. The Principled Podcast brings together the collective wisdom on ethics, business and compliance, transformative stories of leadership and inspiring workplace culture. Listen in to discover valuable strategies from our community of business leaders and workplace change makers. Susan Divers: Good afternoon. From time to time, but particularly in the last few years, federal regulators have provided detailed guidance on what they expect to see in ethics and compliance programs when companies present them as a defense to misconduct inquiries or investigations. What do the recent flurry of reports, policies and guidance mean for compliance professionals? How should they be applied to improve E and C programs? Hello, and welcome to another episode of LRN's Principled Podcast. I'm your host, Susan Divers, director of thought leadership and best practices at LRN. And today, I'm joined by Jon Drimmer, a partner at the international law firm of Paul Hastings. We're going to talk about the recent DOJ guidance and policy impacting corporate compliance programs and ethical culture, and hopefully help everyone understand what it is and how they should apply it to their programs. Jon is a real expert, as well as a friend in this space. He has the unusual distinction of serving in three of the principal seats that affect ethics and compliance, once as a federal prosecutor at DOJ, another time as a chief ethics and compliance officer and deputy general council for a large mining company, and now as an ethics and compliance advocate with a leading law firm. Jon, thanks so much for joining me at Principled Podcast. Jon Drimmer: Thanks, Susan. It's great to be with you. Susan Divers: Super. Well, let's jump right in. Last week, we saw a new policy come out of the Department of Justice that both Lisa Monaco and also Ken Polite have talked about with great emphasis. We've also seen the report come out of the sentencing commission about their 30 years of accomplishments. And we've also seen some major guidance in the last two years. Can you put it in perspective for us and talk about how it fits together, and how they interplay. And then we can jump in and start figuring out what they mean. Jon Drimmer: Yeah. No, happy to do it. So let me take each one in sequence. So what we saw come down from the deputy attorney general was a new policy memo. And in essence, what that means is policies are, they are the rules that apply to federal prosecutors and prosecuting entities around the country. They are the standards that are going to be applied. Guidance, which is something that we see come out in a number of different ways through formal guidance as well as through statements and speeches and other informal approaches, this is basically how those rules are interpreted, how prosecutors should be thinking about the application of those policies as they're applied to any given circumstance. And then finally, reports, and you mentioned the sentencing commission's 30 year look back, those are more general. And they do tend to come out for transparency purpose, they're often retrospective, like the sentencing commission report. But they generally talk about how these rules have been applied. So policies are the rules, the guidance effectively aids in their interpretation, and the reports generally are a bit of a look back as to how they have been applied to date. Susan Divers: That's really helpful. It really helps me put all of those in perspective. Talk a little bit more than about the policies and the guidance. Are they mandatory? Are they voluntary? Jon Drimmer: Well, for prosecutors, they're mandatory. So when you look at the policies, this is effectively how prosecutors are to approach any given situation. It is a directive to them in terms of how it is they should go about doing their jobs. And I'll tell you it's critical. It's critical for chief compliance officers to understand those types of initiatives, those types of emphases. It's critical to prosecutors as well, as they get that direction in terms of what they should be focusing on. So really, it's a very important part of the process and helping to shape how investigations are run and scoped from the government's end, and what can be expected on the company side as well for chief compliance officers. Susan Divers: But it's not technically a rule, if I'm correct. But it sounds like you strongly recommend that ethics and compliance professionals pay great attention to it. Jon Drimmer: Yeah, yeah. No, that's fair. It's not a regulation. It isn't something that goes through a formal regulatory process. It's not the equivalent of a law. It's a direction. It's a directive that's basically given. And so it doesn't have the force of law, but it is a very important set of instruments to understand the relevant DOJ policies, the justice manual. So yeah, that's a fair assessment. I do strongly recommend understanding it in detail, but it isn't technically a law or regulation. Susan Divers: And if I understand correctly, and I've been in this situation myself too as a chief ethics compliance officer, if there's a misconduct inquiry or investigation, and 95% of those are resolved without prosecution or probably more, basically, you'll be asked to come in and meet with the Department of Justice prosecutors, possibly the SEC too, and part of that is talking about your ethics and compliance program. Can you put that in context and explain why they want you to do that, and how you should do it? Jon Drimmer: Yeah, absolutely. So what they're really looking for is a discussion of A, what the compliance program was at the time of the incident in question, and where it is today at the time of charging. It's really both time periods are really quite important to them. And they want to understand how with a compliance program the issue or event might have occurred. But they also want to understand what changes have been made to improve its effectiveness since that time period. And often, given the way that investigations go and timelines, there may be a good bit of time between the original incident and the time a formal compliance program presentation is ultimately made. And in making that presentation, the guidance, the policies, these are incredibly important in shaping the factors that you're ultimately going to present on. But the real tip is not just presenting on the formal approach, the formal program, the policies, procedures. But how do you know they are working in practice? And that has been a huge emphasis from the government in the last couple of years, and one that ethics and compliance professionals should take heed of. It's not just a matter of rolling out the program, but with the rollout, including those steps to validate its effectiveness in mitigating the relevant risks it's designed to address. Susan Divers: I want to get into that in more depth in just a second. But before we leave sort of setting the scene for why this is so important. So if you go in and you meet with the Department of Justice and its prosecutors, and you do a good job, a credible job, of presenting your ethics and compliance program, and it's clear that it's a strong program, and you've got hopefully evidence of effectiveness, what's the consequence of that? Jon Drimmer: Well, at the end of the day, I mean, the most significant issue is monitors. And if you've been involved in an issue that violates a federal law, federal criminal law, and the question is: Are you sufficiently capable of addressing your compliance issues going forward without day to day regular oversight from a monitor? That is a critical inquiry, and so number one, an effective compliance program and design and implementation is really important for a monitor. It's also important in charging decisions. It can be important in terms of disgorgement and fines and penalties as well. It's taken into account in the federal sentencing guidelines. So in the end, an effective compliance program really is a critically important part of a resolution process for a DOJ investigation. Susan Divers: So that's basically why ethics and compliance programs, if I understand correctly, came into being. It's really to mitigate the impact of misconduct investigations, and hopefully allow the company to go forward with it's E and C program. We won't talk about monitors today. That can be another podcast. But that's something that you want to avoid, generally. Jon Drimmer: Yeah. You generally want to avoid that, yeah. I mean, look, there's another element we probably won't get into today as well, that you and I have talked about extensively, and that is how programs ultimately help shape the values and culture of a company, so aside entirely from proactively mitigating relevant risks, affirmatively driving a culture that does increase productivity, increase retention, increase morale, that's a critical component of a compliance, an ethics and compliance program as well. It does dovetail a bit with culture of compliance, which is something that is important to demonstrate when you're in front of the government. It's something the government is increasingly emphasizing. There's a positive aspect that isn't just preventing potential problems from happening that are associated with ethics and compliance programs, as you've written about quite persuasively. Susan Divers: Well, you too. And I'm glad you reminded everybody of that because that is a critical reason for having an effective ethics and compliance programs. So let's leave the sort of rewards and penalties side and start talking about: What are the prosecutors and the Department of Justice leadership really saying in this plethora of policies, guidance that's come out in the last couple of years? What are the key messages? Jon Drimmer: Yeah. I would say in reading through the recent speeches, the policies, coupled with the guidance, I think we can take away several messages. And two of them are, number one, there is this enormous focus on program effectiveness, and I can't say that enough. And as I read the memo from the deputy attorney general colloquially calling the Monaco memo, I see as a major sub theme, and as a former chief compliance officer, this absolute drive towards the effectiveness of programs. And just to take a step back for a minute, in some ways, this is how the sentencing commission's report actually becomes relevant in this discussion, and the 30 year look back report was issued roughly at the same time as the DAG memo. And if you look at the report, a few interesting statistics jump out. And these again, this is focusing on companies that actually went through a court sentencing, so it isn't settlements, which is typically how corporate resolutions are resolved. But 2021 was the first year that more than half of the companies sentenced under the guidelines had a compliance and ethics program. And the previous high was 2018, when it was about 28%. But in 30 years, since 1992, only 11 companies have had a reduction by a court because their compliance program was effective. That's .5% of all of the companies sentenced, and most of those are actually small companies. So most of the time, for those companies that are going through the process, they aren't getting credit for having an effective program. And with the Monaco Memo, if you actually look at a lot of what policies are ultimately looking to drive, it does center around effectiveness, driving performance, driving commitment through a focus on individuals. And so it talks about producing information in a timely way, focusing on individuals because that is what incentivizes effective performance. For chief compliance officers, it might mean if you're going to do an investigation, a thorough investigation, you do have to include that within your scope, the focus on individual culpability to a degree that you might not have before. The same is true with ephemeral messaging, which is a big emphasis in the recent memo. Ephemeral messaging has been part of their calculus for several years now. But here, they do want to focus on whether the company policies regarding ephemeral messaging are effective. Is the company capturing messaging that's occurring on company related devices? Are we allowing personal devices? If so, are they limited to certain apps that are capturing company business related discussions? Is there training? Is there auditing? Are there other steps on ephemeral messaging? So they really want to see not just: Are there policies? But are they effective? And those are just two examples. But if you do dig into what's behind a lot of these policy announcements in the memo, it really is looking to drive effective programs. Susan Divers: Well, I want to dig in a little bit. And just to clarify by ephemeral messaging, you mean that if we have senior execs using What's App to communicate, rather than company systems that are subject to discovery, then we might have a problem. Jon Drimmer: Yeah. It can be company, it can be teams messaging, it can be What's App on company issued devices or personal devices. It's any of the messaging systems that are used to communicate that ultimately may not ordinarily be retained by the company in the way that email is. Susan Divers: So that's an area that the policy makes clear, compliance officers ought to really take a hard look at and may need to make some changes, or at least provide some clarity. I want to get information effectiveness more in a minute too. But just to deal with the other very specific granular recommendation that I saw in the Monaco Memo, it was that you really have to have an incentive system that's aligned to ethics and compliance. And by that, it's both positive and negative. In other words, you have to reward ethical behavior as part of your system of incentives, whether it's bonuses, compensation, promotions. And you have to penalize misbehavior, whether it's bonuses, compensation, promotions, but also claw backs. Can you talk about that a little bit? Jon Drimmer: Yeah, yeah. It really was fairly prescriptive, as you say, in terms of, in ways that I think should make chief compliance officers happy. That's the stuff that we always advocate for with human resources and with executives. Hey, we want ethics. We want ethics and compliance included in hiring decisions and promotions and bonus frameworks and performance commitments. And that's really what helps integrate ethics and compliance into business operations and prioritize it along with operational considerations, so that should be welcome news for chief compliance officers. The claw back aspect, which is the stick, that's the carrot, this is the stick, it's interesting. They really emphasize it's not good enough just to have claw back provisions that are theoretically applicable, that are present in policies and are never applied. They want to see them applied in cases where there is appropriate individual culpability. And that may mean applied in different ways. They're clearer that there is no uniform approach to a claw back provision, but it isn't good enough just to have it as a policy. You need to talk about it. You need to train on it. And you need to actually implement it in appropriate situations, which is part of the focus on the individual responsibility and again, driving effectiveness. Susan Divers: That's a very good segue into effectiveness. I do want to emphasize what you said, which is this is something that ethics and compliance professionals need to pay attention to. And it should be a welcome development to have that kind of accountability and importance placed on ethics and compliance considerations. But it's: What do you do about it, as you said, if you've got claw back? I think the SEC says that about 50% of publicly traded companies have claw back, but you have to use it. Otherwise, you're probably worse off if you have it as a tool and then you don't use it if you've got senior level misconduct. Jon Drimmer: Yeah, I think that's right. But better to have it than not have it, and if you've got it, you've actually got to apply it, is kind of what they're signaling. But look, this is hard. I mean, it is really hard when you are doing investigations of your own people. As a chief compliance officer, this was the least favorite part of my job is doing investigations into people I work with, people I knew, people who in other aspects of my job, I had to trust. I had to trust them in terms of implementing or overseeing certain aspects of the program. And when you have to do an investigation into them, it feels lousy. It screams out for why independence is important. And those particular instances is just a matter of investigative integrity, but it's a lousy part of the job. And applying a claw back provision to senior executives who you have worked with, who you have traveled with, whatever it is, it's a lousy part of the job, but they are saying it is an important part and a part that has to be applied in practice. Susan Divers: Yeah. I agree with you. That is really the worst part of being a chief ethics and compliance officer, for sure. Let's dive deeper into effectiveness. As I've gotten to know you and worked with you on thought leadership, I've always been extremely impressed with you focus when you're a chief ethics and compliance officer on effectiveness. And I remember some of the things you did, even including short pulse surveys in your investigations to get feedback from employees, so that's just one example. But can you talk about what do we really mean by effectiveness in terms of ethics and compliance programs? What should we be measuring? What should we be looking at? And where should the focus be? Jon Drimmer: Yeah. I mean, really what effectiveness means is: Are the goals of any particular element of your program being achieved? Are you meeting the goals that you have set out for that particular element of the program? So for instance, your goal might be to roll out a new training, and to roll it out to 90% of everybody on a mapped basis. That isn't going to get into effectiveness. Effectiveness is: How well do they retain the critical aspects of the content that is being conveyed? And that can be done through surveys, that can be done through tests, et cetera. But when we're talking about effectiveness here, again, it isn't just about roll out, it isn't just about robustness and good faith commitment to implementing a program. But is it working in practice? How do you know it? How do you test it? How do you validate it? Often, that's done through KPIs and through metrics. I personally like surveys, sentiment survey, I've always liked surveys as a way of getting information. And beyond that, it brings employees into the program when they are talking to you, providing information about their own experiences. I think that's a very effective way to do it. I think 360s in terms of reviews that include ethics compliance is another important part, so you do again get perspectives of employees on individual performance, particularly for supervisors, from an ethics and compliance standpoint. I think you need to look at audit results. I think you need to look at investigations. I think you need to look at a number of different factors that all indicate on a lag indicating basis, what is working and what isn't working. But I think that should be a relentless focus, personally. And I think for every element of your program, you should be looking at multiple ways to try to assess. Is what I'm doing actually working to the degree that I want it to, and in the way that I want it to? And if not, you have to make an adjustment. That's what effectiveness is about. Susan Divers: That's a really good definition. I think one of the traps people can fall into easily is to focus on activities rather than impact. And I like your phrasing of it as a relentless focus on effectiveness. I mean, one of the things we're just doing is rolling out a short, I think it's 10 question ethical culture pulse survey that comes up at the end of a code of conduct course. And it asks questions about respect and trust and organizational justice, which as you know are key elements of an ethical culture. So always trying to get at perceptions and concerns and to the degree that you can measure how that's playing out, I think is really essential to effectiveness. I want to talk about in a minute how non US companies are affected by all this, and also the most common mistakes you've seen people make in your long and in depth, varied career. But before we get there, I was just looking at some of the DOJ material, and I see that Matt Galvin has joined the team. And now I think there's at least three or four former chief ethics and compliance officers. And Matt came for Anheuser, and he has a particular focus on data analytics. What are you seeing in terms of using data analytics for effectiveness? And what do you recommend in that area? Jon Drimmer: I think that's a great hire. I think it'll be great for Matt, and I think that's a great hire for the government, really bringing in somebody who ran a compliance program and who has had a very substantial focus on data analytics. And at AB InBev, the Brew Right program that he put together is one that's usually been held up as an industry leader. I mean, I do think data analytics is critically important. One of the challenges with data analytics that you have to always get around is making sure that your data is good, that things are being recorded and described in like manners that allows for apples to apples comparison. And you have to understand what to do with that information. And so it's not enough to run the analytics, but when you get the analytics back, you have to have a program in place, resources in place, to act on it. And so thinking through holistically what the data is, where it's coming from, how you're going to act on it, depending on what you get is all a really important part of the equation to think about ahead of time before you just start collecting and running. Look, it's critically important. It's been something that's been emphasized for years as a key way of identifying effectiveness, as well as potential risks that you might not otherwise see, and trends, and patterns. So it really is a very important part of a program with the caveat that you've got to make sure that your data is really good and that you know what you're going to do with it on the back end. But that's a great hire, and I'm sure it's really going to advance compliance thinking in the government around the use of data. Susan Divers: I think that's a good way to characterize the importance of data metrics and particularly stressing that it's not enough to have them and get the insights, you have to act on them. It's similar to risk analysis and risk assessment. It's great that you're running a yearly risk assessment, but are you factoring those results into your training or your policies? So that's part of that focus on effectiveness. Talk to me a little bit, Jon, if you would, about we've been talking about the Department of Justice. It does seem to me that what DOJ does in areas like this has a lot of impact on international companies. It's not limited to the US. And you're in a great position to discuss that a bit, if you would. Jon Drimmer: Yeah, sure. Of course. No, absolutely. Look, and to be clear, when the government emphasizes things like data and benchmarking and metrics and KPIs, I can't applaud them enough for bringing in someone like Matt, who has seen it on the ground, has put into place a great program to really help educate. And that's going to be true for US and non US companies. The government focuses on violations of the law, where there is jurisdiction, where there's something that will touch the US, or you have US companies or US issuers. But if you're a foreign company and you're doing business in the United States, or you're listed on a US exchange, the US laws very well may apply to you. The FCPA certainly very well may apply to you. And some of the biggest settlements, again just sticking with the FCPA, have been with non US companies in the last two years. And I don't want to limit this to the FCPA because the memo from Lisa Monaco, it's not limited to the FCPA, but it will extend to throughout the criminal division. And so whether it's antitrust, or healthcare fraud, or other areas that the criminal division might oversee, this is going to apply to companies regardless of whether they're US or non US, depending on the jurisdictional components, so it's a very important part for all companies doing business in the United States, not just US companies. Susan Divers: And I think sometimes people forget how broad that actually is. People sort of think, "Okay, there's US companies, there's French companies, there's Indian companies," but if you're doing business here, or you're using the banking system, then you are basically within the ambit of US jurisdiction if you commit bribery violations, or antitrust, or sanctions violations, or whatever they happen to be. So it really is a very broad net. And I think for that reason, I think the guidance has driven the evolution of ethics and compliance programs globally, not just in the US. Is that your sense too? Jon Drimmer: Yeah. Yeah. No question about it. I think if you look around the world, whether it's the UK, or France, or throughout Latin America, for those governments that have formally put out either guidances, or they've integrated into their laws what compliance programs ought to look like, I mean, it really looks a lot like what the Department of Justice and the SEC have put out, which of course is premised on a sentencing guidelines foundation. But really, it is driving global compliance processes and programs around the world, even for those companies that don't touch the US, even in their home jurisdictions. It's driving very similar approaches and ways of thinking about compliance. Susan Divers: Yes. And I think if anybody needs proof of that, they should read the Glencore CPA settlement, which I was just looking at, which is a huge fine for anti bribery for basically a non US company. But we're starting to run out of time. I could do this all day, as you know. But let's wrap up with: Given your unique perspective, having sat in all of the key positions, what are the most common mistakes you see people make in ethics and compliance programs? And if you can relate some of those to the guidance, that would be great. Jon Drimmer: Yeah, sure. Look, I mean, I think first and foremost, it isn't really understanding and looking to integrate into programs what drives an ethical culture. And we talked before about the absolute importance of organizational justice as one of the key drivers in thinking about how that should get integrated into your program. And another is managerial modeling. And truthfully, what people seem to often forget is that most employees look at their supervisors, and maybe their supervisors' supervisors as the company. They look at them as management. And so focusing on, quote, unquote, tone from the top, and the most senior leaders of a company, to the exclusion of direct supervisors, middle managers, I think is often a mistake. And so driving behaviors expected of managers is critically important. I think people also ignore the absolute singular importance of confidence in internal reporting mechanisms and hotlines, which is often a proxy for whether your culture of compliance is strong, and whether organizational justice exists, whether managerial modeling is occurring. But I think beyond that, we've talked about the focus on effectiveness. And I think too often, you do see compliance programs that really are driving towards activities and robustness and metrics and numbers that don't take into account. Is it really working in practice? And I do think that has to be, especially in light of the guidance, which talks about culture, it talks about effectiveness, it focuses on effectiveness, I think that's got to be a critical emphasis for any program. And I think a lot of programs aren't sufficiently mature in that particular aspect, which may be why this guidance or this policy is coming out now. Susan Divers: So it sounds like if you were advising let's say a startup, or a relatively small company that's program is just getting underway, you would advise them to focus very much on the value side on getting organizational justice right, on getting speak up culture going and creating that atmosphere of trust, and also on making sure that managers know what the ethical and compliance considerations that affect them are, and what that means in practice. Jon Drimmer: Yeah. Yeah, that's exactly right. And look, that relates directly to the guidance as we look at rewards, in terms of pay, of performance commitments, presumably of bonuses, of promotions. So setting those expectations for management, along with organizational justice and speak up, I think are really vital components. And so if you are just starting out, the sooner you look to embed that within the company, the more effective it's going to be hopefully as the company grows. Susan Divers: Wow, this has been such a terrific, insightful conversation. And I really feel like I've benefited a lot personally just from hearing the way you've wove together the policy, the guidance. And just for one point of clarification before we sign off, I've been looking at the guidance since I think 2013. I've seen an evolution, actually. It's gotten stronger and it's gotten smarter in focusing on the right things like culture. I don't see it really weakening or changing, even during the Trump administration, interestingly. Is that your perception as well? Is that your expectation for the future? Jon Drimmer: Yeah, yeah, absolutely. Look, they are clearly sharpening the guidance. They are sharpening their policies in a way that is actually quite healthy. And I completely applaud the degree of transparency that we've seen in terms of talking about how these are applied, in terms of talking about how these are to be interpreted. So I applaud the transparency and I completely agree. It is getting much sharper, particularly around those aspects that really impact compliance professionals, like culture, like incentivization, like trying to establish commitments, like integrating compliance into employment processes. So I think it is getting smarter. And again, I think the transparency is really helpful, and particularly for chief ethics and compliance officers. Susan Divers: Great. And I agree. I mean, it's actually making people's jobs easier if they take the key messages in the guidance and are able to use the guidance to drive change in their organizations. So Jon, thanks so much for joining me on this episode. Just to wrap up, I'm Susan Frank Divers, and I want to thank everyone for listening to Principled Podcast by LRN. Jon Drimmer: Thank you. Outro: We hope you enjoyed this episode. The Principled Podcast is brought to by LRN. At LRN, our mission is to inspire principled performance in global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us at lrn.com to learn more. And if you enjoyed this episode, subscribe to our podcast on Apple Podcasts, Stitcher, Google Podcasts, or wherever you listen. And don't forget to leave us a review.
A lot is happening at once on JoJo's this week, and we do our best to keep it all straight. It's Episode 19 of Stone Ocean, "Birth of the Green." We also talk about empennages, a pigeon at UPS, seku hara, Pickelhauben, JS Bach, light fixtures, and Bogleech. Bogleech write-ups on JoJo stands (Scroll about halfway down for JoJo's Bizarre Halloween): https://bogleech.com/xedni.html | Rate us nicely on Apple Podcasts | Support us on Patreon | Follow us on Twitter | Subscribe to us on YouTube | Join the fan Discord --- Send in a voice message: https://anchor.fm/jjbpod/message
durée : 00:04:42 - Le Billet politique - par : Jean Leymarie - Après le meurtre de la jeune Lola, à Paris, des élus de droite et d'extrême droite accusent le gouvernement de "laxisme", car la femme suspectée du crime, algérienne, était en situation irrégulière.
Olá papudos! Uma área que, até pouco tempo atrás, era um pouco “marginalizada” e que agora tem investimentos iguais ou até maiores que os casamentos, os ANIVERSÁRIOS INFANTIS. No bate-papo dessa semana, conversamos com a fotógrafa FLAVIA PERRIN, sobre o mercado de aniversário infantil e como conquistar seu espaço dentro dessa área. Ficou curioso? É […]
The watch fam has some ridiculously cool people in it. Nobody stands out as the exemplification of this better than Brock Stevens: Naval diver, Instagrammer (AKA @deepsea_edc), Adventurer, EDC enthusiast, Creative Director at Deep Sea Co AND a watch enthusiast! Enjoy listening to Brock describe his day to day working conditions, harrowing close calls and of course, hear all about the awesome watches he wears while doing it all! Brock's Instagram Page: https://www.instagram.com/deepsea_edc/ Deep Sea Co's Instagram Page: https://www.instagram.com/deepsealocker/ Deep Sea Co's Website: https://www.deepseaco.com/ Support Project Recover by purchasing these specific products: https://www.deepseaco.com/search?q=edc&options%5Bprefix%5D=last Info about Project Recover: https://www.projectrecover.org/ If you or someone you know wants to be on the show or if you have any questions or feedback please contact me at: https://www.instagram.com/ricoswatchespodcast/ or e-mail: email@example.com Thank you! Eric
In this episode, Ross discusses what a Navy Master Diver is and what a Navy Master Diver does. He shares his experiences leading various military diving operations including the recovery of victims and the removal of bridge debris to restore the commercial waterway following the collapse of the Interstate Highway 35 Bridge into the Mississippi River in downtown Minneapolis, Minnesota. Ross was inspired to write a book in part because he enjoys bragging about America's sons and daughters in uniform who he served with during his Navy Career. You can read about the Sailors Master Chief Master Diver Ross Garcia served with and his leadership experiences in his self-published book, “View Through a Faceplate Window, Adventures of a Navy Master Diver.” Learn more about your ad choices. Visit megaphone.fm/adchoices
On this episode Alex talks with Diver, World medallist and commonwealth games gold medallist, Mia. They speak about what it's like in the sport of diving, her journey into the sport and the psychology of a diver. We hope you enjoy this one as much as we did! As always, I want to thank our sponsors... Organic relief- Amazing CBD products at unbelievable prices Use code 'Alex40' to save 40% off https://organicrelief.co.uk/ Link to both my poetry books https://www.thenomadicpodcast.com/books
This week on A Week In Watches we've got a fairly diverse group of releases. Our first stop is some Seiko Prospex divers made out of titanium, then we head to an Ollech & Wajs with a cool bezel, from there we're off to space with Urwerk and their new, nerdtastic 120, and finally, we're back to Germany for some old-school crafts by Benzinger.We've got two (house) sponsors this week. The first is Windup Watch Fair NYC! Yup, it's October, which means that Windup Watch Fair NYC is right around the corner, Oct 21 – 23. This year's show is going to be the biggest and best yet. We have over 60 brands presenting, panels, a bar, and more. To accommodate this, we've moved it to a new locale: the Altman Building at 135 W 18th st. As before, it's free and open to the public, so bring your family, friends, and your wallet too
I met Tommy on the Incline in manitou Springs last week. We got talking about his sky diving, and I shocked to learn that he lost his arm in a sky diving accident, but he has done 700 plus jumps after that accident. He is resilient and the definition of no quit!. His motto is adapt, improvise, and overcome. Check out his website at www.clasplife.org He runs a non profit helping people with almost anything and everything! --- Send in a voice message: https://anchor.fm/tyler-griffith5/message
Rob Fredette and Shawn Donovan discuss the last two albums of the David Lee Roth era. Diver Down and 1984. Diver Down had 5 cover songs and 1984 was the album that put Van Halen into superstardom status. This episode covers warming up for The Rolling Stones, the Diver Down album and some interesting facts of the 1984 album and tour. 1984 was different then their five previous albums. We review the July 5th 1984 concert in Indianapolis in a fun way. Rob and Shawn give their Top 5 songs in the David Lee Roth era. Research Items 1984 Van Halen album cover https://americansongwriter.com/story-behind-1984-van-halen-album-cover/ WRTV Indianapolis on July 5th concert sales https://ultimateclassicrock.com/van-halen-opened-for-rolling-stones-1981/ Please give a follow and listen. Email any suggestions or feedback to firstname.lastname@example.org RJF MEDIA LLC 2022
Rob Fredette and Shawn Donovan discuss the last two albums of the David Lee Roth era. Diver Down and 1984. Diver Down had 5 cover songs and 1984 was the album that put Van Halen into superstardom status. This episode covers warming up for The Rolling Stones, the Diver Down album and some interesting facts of the 1984 album and tour. 1984 was different then their five previous albums. We review the July 5th 1984 concert in Indianapolis in a fun way. Rob and Shawn give their Top 5 songs in the David Lee Roth era. Research Items 1984 Van Halen album cover https://americansongwriter.com/story-behind-1984-van-halen-album-cover/ WRTV Indianapolis on July 5th concert sales https://ultimateclassicrock.com/van-halen-opened-for-rolling-stones-1981/ Please give a follow and listen. Email any suggestions or feedback to email@example.com RJF MEDIA LLC 2022
In the last hour of MCMS, Marc brings out the big dogs: Jessie Jane Duff gets us fired up for the "long week" as they discuss VP Harris, Trump's inspirational speeches over the weekend and the invalid fraud lawsuit against former President Trump. Apparently one school district decided to ban all girls from their own locker room to accommodate a transgender student. KMOX Sports Director Tom Ackerman joins the show to talk Cardinals after the retirement ceremony for Wainos and Pujols over the weekend. Later, a Coast Guard diver was thanked personally by President Biden for his help during Hurricane Ian, just days before he's due to be fired for not complying with the vaccination requirements by the military.
Divers, we've reached the mid-point in our Cyberpunk Series. For episode 5 N&D are Deep Diving Terry Gilliam's 12 Monkeys. This Post Apocalyptic Time Travel Thriller was borrowed from another list, to fill in for Mamoru Oshii's Ghost In The Shell, which N&D already covered all the way back in episode 7.
SKIP TO 00:11:05 TO GET TO THIS WEEK'S STORY THIS EPISODE IS SPONSORED!!! Visit https://www.venterrafarms.com and enter "HAUNTED15" at checkout for 15% off your order + free shipping on all CBD products. Lake Superior is considered to be one of the most haunted lakes of all time due to the insanely high number of unrecovered shipwrecks and bodies that litter the lake floor. In fact, Lake Superior has earned two foreboding nicknames: “The Lake That Never Gives Up Her Dead” and “The Graveyard of the Great Lakes”. Lake Superior has also earned the title of being one of the “Top 10 Most Haunted Lakes in the World”. Today we learn about the most famous of all of the bodies still entombed on the lakebed floor: “Old Whitey”. Whitey's corpse is found floating inside the engine room of the SS Kamloops, which sank on the Canadian side of Lake Superior in the 1920s and has never been removed. Divers report seeing Old Whitey's corpse AND his ghost floating around the ship, following them throughout the wreckage. And if that weren't scary enough, we also delve into the the fear known as “submechanophobia”, which Aly definitely has. TIME STAMPS 00:00:00 INTRO 00:11:05 SUBMECHANOPHOBIA 00:27:41 LAKE SUPERIOR 00:41:38 SS KAMLOOPS 01:30:00 OLD WHITEY 01:53:30 KAMLOOPS SCUBA DIVER INTERVIEW 02:27:35 FINAL THOUGHTS Please go leave a comment on Curtis Lahr's Kamloops vlog and say that LGH sent you! He was super cool to come on the show and talk about such a controversial story. Click here to go to his vlog now: https://bit.ly/CurtisKamloops —— Other Important Stuff: Buy Our Merch: https://www.letsgethaunted.com Donate to our stupid show: https://ko-fi.com/dogmomusa Check out the photo dump for this week's episode: https://www.instagram.com/letsgethaunted Send us fan mail: PO BOX 1658 Camarillo, CA 93011 Send us your listener stories: LetsGetHauntedPod@gmail.com — BACKGROUND MUSIC BY MICHAEL GELFI STUDIOS SUPPORT HIM ON PATREON: https://www.patreon.com/MichaelGhelfi Link to sound: https://www.youtube.com/watch?v=h_oZIrPV_iU FIRE SOUND EFFECT BY N BEATS Link to sound: https://www.youtube.com/watch?v=mz9ftphTWTM — SOURCES:  “Submerged Cultural Resources Study: Isle Royale National Park” by Daniel J. Lenihan, the Submerged Cultural Resources Unit, and National Park Service, Link: https://bit.ly/3BBcozs  The Youtube channel “Ask A Mortician”, video “The Lake That Never Gives Up Her Dead”, Link: https://bit.ly/3RIyqWM  “Lake Superior is one of the Most Haunted Lakes in America” by Paisley Dunn for QuickCountry.com, link: https://bit.ly/3Dn8mMl  “Meet Old Whitey, the Preserved Corpse of the SS Kamloops, Lake Superior's Most Haunted Shipwreck” by Greg Newkirk for WeekInWeird.com, link: https://bit.ly/3U87gdp  “Stone now marks burial plot for SS Kamloops tragedy” by Jodi Lundmark, link: https://bit.ly/3Ua1FTS  Library of Congress, Collections of the State Historical Society of Wisconsin. Volume 16 link: https://bit.ly/3U87LEj
Divers have found a swathe of World War II-era bombs in a lagoon in Tuvalu as part of Operation Render Safe, involving the navies of Australia, New Zealand, and Canada, alongside the US Marine Corps. The explosives are thought to have been dumped by the US military at the end of the war. Now, the question is how best to dispose of them. HMNZS Manawanui commanding officer John McQueen spoke to Guyon Espiner.
A huge thank you to HSBC for powering this week's episode. Whether you're at the very beginning of your wealth creation phase and taking your first steps in investing or you're starting to think about passing your wealth and values to the next generation - HSBC can connect you to global opportunities at every stage of your wealth journey. Click here to find out more! Helloooooo! This week we're talking investing personalities that are made up by yours truly - Sim & Sonya. We bring you four personalities: The Diver, The Structural Seeker, The Thrill Seeker and The Nana Investor. Which one are you? For more Girls That Invest: Instagram TikTok Twitter Facebook Till next week team, Sim & Sonya xo
Joining Laura on today's episode is professional high diver, CEO of the International High Diving Institute—America's first high-diving facility, and founder of the Clean Cliffs project, Ellie Smart. Their conversation begins with Ellie's journey from childhood dreams of diving at the Olympics to the tough realization that she wouldn't reach that standard and her decision to retire from diving during college. She shares the challenges of walking away from the sport that defined her, finding her worth outside of diving, and finally discovering her purpose in cliff diving. Ellie then discusses how she made the move into professional high diving, started competing, and eventually made it onto the Red Bull Cliff Diving World Series as a permanent diver. Next, Ellie talks about her desire to keep challenging herself and working on new dives—including one partly inspired by Laura—so that she can continue unlocking her potential to the highest degree. She also speaks to how she and other cliff divers manage their fear, pointing out that fear can be a good thing physiologically, but only if we learn how to control it and use it in a healthy way. Ellie takes a moment to discuss the impact of social media and how she uses it as a tool while enforcing personal boundaries to ensure she avoids the urge to compare herself with others. Closing out the episode, Ellie reveals some of her pursuits when she's not diving herself, including creating the High Diving Institute at the Utah Olympic Park and co-founding Clean Cliffs, a project with the mission to prevent plastic pollution in the world's bodies of water. Episode Highlights: Walking away from and coming back to diving Learning to cliff dive and starting to compete Unlocking potential and managing fear Creating the International High Diving Institute Giving back with Clean Cliffs Quotes: “I wanted to represent Team USA, I wanted to go to the Olympics, and I would practice my gold medals speech in the shower every single night as a kid and my autograph. In class, I used to get in trouble all the time for practicing my autograph.” “The answer is always ‘no' if you never ask, so I would rather ask and get the answer ‘no' than not ask at all and maybe miss out on a really cool, incredible opportunity. So I definitely get embarrassed or shy or self-conscious sometimes when I have things that I really want to do, like, it's definitely not just easy. But I know that the reward of asking and what could come of it is so much better than not asking.” “It was also very humbling to realize that if I was going to keep diving, I needed to dive for me and not for the results or what it looked like from the outside to other people. Because there's always going to be something bigger and better and different that you can do if you're basing your life on decisions or opinions of other people.” “I really think comparison is just the absolute worst thing that you can do. And so, I try to eliminate that as much as possible from my everyday life. So you know, if any of my friends are listening to this, I love you, but I'm not going to watch your Instagram stories. You can tell me all about it in person.” “I think that that's the most exciting thing about life is we don't know, we get to figure it out as we go. And, you know, I used to have a different approach of, ‘I want to know the answer now. I want to know what I'm supposed to do.' And now I have this whole new mindset of, ‘I'm so excited to see what I can do versus what I'm supposed to do.'” Pursuit of Gold Podcast is brought to you by Kaatsu Global Links: The Pursuit of Gold 1-on-1 Coaching with Laura The Confidence Journal Life at 10 Meters: Lessons from an Olympic Champion Laura's Social Media: Laura's Instagram Laura's Facebook Ellie's Social Media: Ellie's Instagram
Falamos sobre tanta coisa. Tem dedo quebrado, voltar a correr, tênis minimalista, triatlo, sobrecarga, correr por diversão ou performance, hipertensão, tênis com placa e esporte na política. Escuta que ficou bem legal. SEJA MEMBRO DO CANAL DO YOUTUBE Siga quem faz o PFC Debate: Gigi, Camila e Duda.
Duji is mad that the studio trash is no emptied. Dirt bike rider gets sent to prison for 17 months. Adam Levine had an affair with an Instagram model and tried to name his baby after her. Nine-year-old Australian boy bursts into tears of joy as he hits a hole-in-one. Diver who found missing California teen Kiely Rodni says death reeks of foul play. Honda blasted for ordering hundreds of workers at Ohio factory to repay part of their bonuses. Radio guy was secretly recorded screaming at his co-host.
Dr Kostja Makarovic (37) has a PhD in material science. He works in the R&D department of a technological company. He is a passionate diver, exploring coasts, rivers and lakes. He enjoys skiing, mountaineering, mountain biking, hiking and traveling. He also has indoor hobbies such as ham radio and constructing inovative devices for diving. He has been vegetarian since 2001 and raw vegan since 2012. With his partner and child he has two fruit orchards which will supply a good portion of their food in the coming years.Learn more about UK Fruitfest: http://fruitfest.co.uk
The Go-Giver is a classic bestseller that brings to life the old proverb "give and you shall receive. The term "go-giver" is known for defining a set of values embraced by tons of people around the world. This timeless story continues to help its readers and listeners find fulfillment and greater success in business, in their personal lives, and in their communities. If you want a short book that breaks down the core values of business into 5 simple parables... look no further!Remember, with each episode, we will provide a helpful Deep-Dive infographic where we break down the entire book on to 1 page! And we have a convenient link for you to find all of them! Visit invictusmultifamily.com/notes to find all of the sophisticated investor notes!Here are our top 5 takeaways:ValueCompensationInfluenceAuthenticity ReceptivityTweetable Quotes:"Stop looking at your damn phone. Try your damnedest, when you're with somebody to be like, okay, you're the only person in this room." – Anthony Vicino"If you put others' interest first, try to provide value to them first and foremost, then the rest should work itself out somewhere along the line for you." – Dan KruegerLEAVE A REVIEW if you liked this episode!!Keep up with the podcast! Follow us on Apple, Stitcher, Google, and other podcast streaming platforms.To learn more, visit us at https://invictusmultifamily.com/**Want to learn more about investing with us?**We'd love to learn more about you and your investment goals. Please fill out this form and let's schedule a call: https://invictusmultifamily.com/contact/**Let's Connect On Social Media!**LinkedIn: https://www.linkedin.com/company/11681388/admin/Facebook: https://www.facebook.com/invictuscapitalventures/YouTube: https://bit.ly/2Lc0ctX
The Diver from the volunteer dive team Adventures with Purpose says that from what he saw when he found Kiely Rodni's body inside of her vehicle submerged in the reservoir, that he suspects whatever happened that it involved foul play. Authorities have said that they will not be offering any updates in the case until November. (commercial at 11:25)to contact me:firstname.lastname@example.org:https://www.foxnews.com/us/kiely-rodni-volunteer-dive-team-found-remains-suspects-foul-play
Thanks so much for listening! For the complete show notes, links, and comments, please visit The Grey NATO Show Notes for this episode: https://thegreynato.substack.com/p/newwatchessept2022
Law enforcement divers searched a river and area near where the murders of Maggie and Paul Murdaugh occured. Why now? Why there? Alex's attorney said he was at his mother's house at the time of the murders. We talk to a local about what route Alex would have taken from the murders to his mom's house. Does it make sense where they were searching would be a place Alex could have ditched a gun? Alex's attorneys and the prosecutor get testy during a hearing. Our legal analyst, John Snyder, breaks down what they were arguing about and if their nasty behavior was unusual Learn more about your ad choices. Visit megaphone.fm/adchoices
In December of 1995, 41 year old Marilyn Rynn disappeared after attending her workplace Christmas party. Two weeks later her body was found hidden in bushes at a park near to her home. She had been attacked as she took a shortcut on her journey home. A combination of cutting edge forensic techniques and old fashioned police work solved her murder 8 months later. ********* Find us on Facebook or Twitter! With thanks to our supporters on Patreon! Donate today to get access to bonus and ad-free episodes! Check out the Mens Rea Merch Store! ********* Theme Music: Quinn's Song: The Dance Begins Kevin MacLeod (incompetech.com) Licensed under Creative Commons: By Attribution 3.0 License http://creativecommons.org/licenses/by/3.0/ Additional Music: Allemande (Sting) by Wahneta Meixsell. Licensed under Creative Commons: By Attribution 3.0 License http://creativecommons.org/licenses/by/3.0/ ********* Sources: Marese McDonagh and Charles Mallon, “Fears grow for missing Marilyn” in The Evening Herald (29 December 1995) p.p. 1-2. “Gardai plan new searches for JoJo” in The Irish Independent (29 December 1995) p. 6. Marese McDonagh and Eugene Moloney, “Families fear for growing list of missing women” in The Irish Independent (30 December 1995) p. 7 “Woman's body found” in The Sunday Tribune (31 December 1995) p. 3. Jim Cusack, “Report of missing woman waiting for bus diverted gardai in their search” in The Irish Times (8 January 1996) p. 5 Marie O'Halloran, “Poorly lit laneway may have been a short cut to tragedy” in The Irish Times (8 January 1996) p. 5. Marie O'Halloran, “Brother had expected the worst after woman was missing for a fortnight” in The Irish Times (8 January 1996) p. 5. Jospeh Power, “Missing women search hit by computer inadequacies” in The Sunday Independent (31 December 1995) p. 1-2. “Body found on beach” in The Irish Independent (2 January 1996) p. 3. “Missing woman plea” in The Irish Independent (2 January 1996) p. 3. “Marilyn: new plea by gardai” in The Evening Herald (2 January 1996) p. 2. “Gardai in missing woman appeal” in The Evening Herald (6 January 1996) p. 42 Veronica Guerin and Charles Mallon, “Silent phone clue in hunt for woman” in The Irish Independent (7 January 1996) p. 2. Brendan Farrelly, “Valley search reveals grisly scene” in The Irish Independent (8 January 1996) p. 8. Jim Cusack, “Delay in finding body could hamper murder investigation” in The Irish Times (9 January 1996) p. 1 Brendan Farrelly And David Murphy, “Naked corpse sparks hunt for sex killer” in The Irish Independent (8 January 1996) P. 8. David Murphy, “Neighbours recall private woman who loved children” in The Irish Independent (8 January 1996) p. 8. Tom Brady, Brendan Farrelly and David Murphy, “Riddle of calls in Marilyn murder” in The Irish Independent (8 January 1996) p. 1, 8. Jim Cusack, “Killer probably had been scratched, gardai believe” in The Irish Times (11 January 1996) p. 8 Stephen Rae, “Marilyn: Raped, Strangled” in The Evening Herald (8 January 1996) p. 1-2. Annemaria McEneaney, “Colleagues mourn hard worker with a big heart” in The Irish Independent (8 January 1996) p. 8. Frank Kilfeather, “Gardai are puzzled by murder victim's route” in The Irish Times (12 January 1996) p. 5. Fergus Black, “'Valley of fear' in wake of sex killing” in The Irish Independent (9 January 1996) p. 3. Jerome Reilly, “Family's despair as Marilyn laid to rest” in The Evening Herald (9 January 1996) p. 6. Stephen Rae, “Marilyn's brave fight for her life” in The Evening Herald (9 January 1996) p.p. 1, 6. Stephen Rae, “Marilyn killer hunt hots up” in The Evening Herald (10 January 1996) p. 2. Tom Brady, “Gardai sift list of fiends for killer” in The Irish Independent (10 January 1996) p. 4. “Suspect list in killer hunt” in The Evening Herald (11 January 1996) p. 6 Stephen Rae, “Marilyn” Detective probe 'date' theory” in The Evening Herald (11 January 1996) p. 2 “Gardai in new hunt for killer” in The Evening Herald (13 January 1996) p. 4. Tom Brady, “Ten shortlisted in Marilyn murder” in The Irish Independent (13 January 1996) p. 7. Jim Cusack, “Investigation dogged by error and ill-luck” in The Irish Times (13 January 1996) p. 7. Kathy Sheridan, “Woman who enriched lives of her family and colleagues” in The Irish Times (13 January 1996) p. 7. Veronica Guerin, “Jigsaw trail to Marilyn's murderer” in The Sunday Independent (14 January 1996) p. 38. Susan McKay, “Fear stalks the valley where Marilyn died” in The Sunday Tribune (14 January 1996) p. 7. Ann O'Loughlin, “Gardai probe shortcut stalker theory” in The Irish Independent (15 January 1996) p 8. “Gardai appeal to 'Brickie' in Rynn murder” The Irish Times (16 January 1996) p. 3. “Divers check river bed for clues” in The Irish Independent (17 January 1996) p. 16 Feargal Keane, “Rynn murder: acquaintance not a suspect” in The Sunday Tribune (21 January 1996) p. 1. Veronica Guerin, “Gardai not sure Marilyn took bus” in The Sunday Independent (21 January 1996) p. 7. Paul Williams, “Rynn suspect is known sex killer” in The Sunday World (28 January 1996) p. 11. Catherine Murphy, “Worlds apart, but united in fear” in The evening Herald (29 January 1996) p. 6-7. Stephen Rae,” Marilyn: Two held” in The Evening Herald (29 January 1996) p. 1. "Man is held for Joyce murder” in The Evening Herald (30 January 1996) p. 1,2. Tom Brady, “Gardai say the list of suspects is narrowing” in The Irish Independent (30 January 1996) p. 11. Jim Cusack, “Man and teenage girl questioned about murder of Galway farmer” in The Irish Times (30 January 1996) p. 1. Tom Brady, “Murder hunt gardai 'start afresh' in clues search” in The Irish Independent (5 March 1996) p. 9 Stephen Rae, “Rynn murder: Man on bus link” in The Evening Herald (12 March 1996) p. 2. Stephen Rae, “Gardai close in on Marilyn killer” in The Evening Herald (13 March 1996) p. 6 Jim Cusack, “Rynn murder inquiry takes fresh direction” in The Irish Times (16 March 1996) p. 1. Alan O'Keefe, “New Rynn murder suspect” in The Irish Independent (17 March 1996) p. 2. “Marilyn suspect in suicide” in The Evening Herald (22 March 1996) p. 4. Stephen Rae, “Man is held for murder of Marilyn” in The Evening Herald (6 August 1996) p. 12. “Baltinglass man is charged wth murder” in The Wicklow People (8 August 1996) p. 10. Ray Managh, “Marilyn murder charge man is bailed” in The Evenign Herald (13 August 1996) p.p. 1-2 Ray Managh and David Murphy, “ Marilyn accused to stay with parents” in The Irish Independent (14 August 1996) p. 11. Tim Healy, “1000 witnesses in Rynn case” in The Irish Independent (11 December 1996) p. 4. “Rynn murder charge man remanded” in The Evening Herald (4 February 1997) p. 5. “Rynn case: new remand” in The Irish Independent (5 March 1997) p. 6. Stephen Rae, “Trapped by his own hand” in The Evening Herald (26 January 1998) p. 16 – 17 Don Lavery, “Genetic technique crucial to gardai” in The Irish Independent (27 January 1998) p. 13. Diarmaid MCDermott, “Murderer 'overcome by impulse' gets life” in The Irish Independent (27 January 1998) p. 13. For a full list of sources, see mensreapod.com