Listen!!!! The crew is back at the table getting real to heal! We have B, EC, and Molove coming together to discuss some of the chivalrous acts that some men were trained to do, while others had learn later in life, or, are still learning. Those acts like opening the door for a lady, a lady allowing this and waiting for the man to do so, and even learn some new game on bringing flowers to a date. Listen in on the discussion around, “Good Morning,” texts and why the bar gets moved sometimes. We're at the table to get you all talking, so let's keep coming to get real and heal! #Letsgetrealtoheal #HSSSpodcastia Show Links: linktr.ee/hssspodcastia --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/hesaid-shesaid7/message Support this podcast: https://anchor.fm/hesaid-shesaid7/support
Your LO tells you, “all done,” after peeing in the potty, but when she stands up there are extra dribbles. Today Nicole will share some strategies to help get all of the pee *in* the potty. Get full show notes and add your comments or questions here: https://godiaperfree.com/214 Get my free easy start guide for EC https://godiaperfree.com/start Start EC with your baby today with my popular book, Go Diaper Free: https://godiaperfree.com/thebook
How do you know if your ethics and compliance program is successful? How are you capturing data and comparing it to industry benchmarks, or tracking your own company's trends over time? In this episode of LRN's Principled Podcast host Emily Miner, director of Advisory Services at LRN, talks about benchmarking E&C data with her colleague Derek Clune, product manager of Data & Analytics. Listen in as the two explore how benchmarking practices come to life and the role AI plays in LRN's new Catalyst Reveal solution. Featured guest: Derek Clune Derek Clune has been working in the ethics and compliance space for over 5 years with an emphasis on data and analytics. As a Product Manager at LRN, Derek is responsible for the vision of LRN's new data and analytics platform; Catalyst Reveal. His main goal is to provide E&C professionals with more actionable data to understand their E&C program effectiveness better. Derek's team works to create products that offer best-in-class prescriptive interventions to improve E&C programs and ease the administrative burden. 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. Find the transcript for this season 8 episode at LRN.com.
Join B, Molove, and EC at the table to get real and heal as they discuss who is qualified to give relationship advice. This topic stems from a social media post that stated, "Ladies stop taking relationship advice from single women. She's not speaking from experience," which was posted by a mutual friend of Molove and B's, and needless to say, Molove had some questions and some things to get off her chest. Tune in and decide who is qualified, capable, or has the potential to give relationship advice, and whether or not they should. Let's keep coming to the table to get real to heal! #Letsgetrealtoheal #Letsgetrealtohealanddobetter #Advice --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/hesaid-shesaid7/message Support this podcast: https://anchor.fm/hesaid-shesaid7/support
With 19 National and 5 World Championships split between BMX and mountain biking to his name, Eric Carter is a living MTB legend. EC came over to MTB from BMX in the heyday when pay was big and the partying even bigger. I learned so much from EC during my years racing and owe a ton to the man. His attitude to life and racing was incredible and was always a good time being around the man. Enjoy some incredible stories from over the years. An Episode not to be missed.
How do you start EC with a newborn who has been in the NICU and may have delays? Today my new guest host, Nicole, will discuss some strategies and considerations for practicing EC with a delayed or special needs child. Get full show notes and add your comments or questions here: https://godiaperfree.com/213 Get my free easy start guide for EC https://godiaperfree.com/start Start EC with your baby today with my popular book, Go Diaper Free: https://godiaperfree.com/thebook
Met vandaag; Voorzitter ondernemingsraad BNNVara over angstcultuur op de werkvloer van DWDD | Wat is de rol van de politie-agent in de huidige gepolariseerde samenleving? | EC moet besluiten wat te doen met het subsidiegeld voor Hongarije | Eelco Meuleman: een vrolijke kankerpatient | 5v12: Gedicht voor Groningen. Presentatie: Chris Kijne.
As the world emerges from a pandemic mindset, we find ourselves confronting new geopolitical realities with Putin's war in the Ukraine as well as increasingly fraught relations between the US and China. How is this geopolitical landscape changing the compliance landscape? In this episode of the Principled Podcast, host Susan Divers is joined by Tom Fox, the founder of the Compliance Podcast Network and aptly accredited “Voice of Compliance.” Listen in as the two discuss the impact of geopolitics on ethics and compliance, and what issues should be top-of-mind for E&C leaders in the near future. To learn more, download a copy of Tom Fox's white paper Never the Same: Five Key Areas in Which Business Will Never Be the Same After the Russian Invasion. Featured guest: Tom Fox Tom Fox is literally the guy who wrote the book on compliance with the international compliance best-seller The Compliance Handbook, 3rd edition, which was released by LexisNexis in May 2022. Tom has authored 23 other books on business leadership, compliance and ethics, and corporate governance, including the international best-sellers Lessons Learned on Compliance and Ethics and Best Practices Under the FCPA and Bribery Act, as well as his award-winning series "Fox on Compliance." Tom leads the social media discussion on compliance with his award-winning blog, and is the Voice of Compliance, having founded the award-winning Compliance Podcast Network and hosting or producing multiple award-winning podcasts. He is an executive leader at the C-Suite Network, the world's most trusted network of C-Suite leaders. He can be reached at email@example.com. 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: General Pete Schoomaker made a remark some years ago that's always stayed with me. He said, "People like to think that life is an opera that unfolds over several acts, but it's really a rodeo. You never know what's coming out of the shoot." So much of the ethics and compliance sphere clearly demonstrates the truth of the general's remarks, especially recently. LRN's last two program effectiveness reports focused specifically on the impact of the pandemic on ENC programs. Now we have the war with Russia in the Ukraine and increasingly fraught relationships with China. How is the geopolitical landscape changing the compliance landscape? 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. Today, I'm joined by Tom Fox, the founder of the Compliance Podcast Network and aptly accredited Voice of Compliance. In addition to his 30 plus years of legal experience, Tom is the author of the award-winning FCPA Compliance and Ethics blog, and The Complete Compliance Handbook now in its third edition, which is by far the best source for best practices in one place about ENC programs. We're going to be talking about the impact of geopolitics on ethics and compliance and what issues should be top of mind for ENC leaders in the near future. Tom, welcome. Tom Fox: Susan, thanks. I have wanted to be on this podcast for a long time. I particularly enjoyed your reference about rodeos because in the great state of Texas, that's a college sport, rodeoing, so lots of rodeos and it's certainly an apt metaphor for what we're going to talk about today. Susan Divers: Well, great, Tom and I really appreciate the opportunity to have any conversation with you, but particularly on the podcast. So Tom, first, generally, how do you see the ongoing war in the Ukraine as disrupting trade and the rules, both formal and informal, that have governed the world for the last 20 years and is the World Economic Forum vision of trade now dead? Tom Fox: Susan, in addition to the rodeo metaphor you gave us, the most prescient comment I heard during the COVID-19 pandemic is that we've moved from disaster recovery to business interruption to, excuse me, to business resiliency, to business as usual. Literally now, we can have a weather event, we can have an economic event, we can have a geopolitical event, we can have any event and the requirement of a company is how do you respond? How do you respond tomorrow? Have you planned for this? I think the type of thing that we saw with the Russian invasion, as tragic as that was, it's one more, it's just an event and we're going to talk about that in some detail. But every company has legal, ethical and business obligations around that event. I was also particularly struck by your reference to the World Economic Forum, and when I read that, it put a frown on my face. And it put a frown on my face because the World Economic Forum, in my mind, has been one of the biggest leaders for the global economy. Since at least 1990 when I started paying attention to a global economic framework because I was in the energy industry and began to think about these issues on a global basis, the World Economic Forum and their symposiums, their position papers and really their raison d'etre was to talk about a global economy. Although I certainly thought we would have regional conflicts, as we have always had, I never thought we would, I guess my hope was that the global economy would help drive us towards a more integrated global community and that we wouldn't be put near a brink again of a global conflict. I don't pretend to say that's where we're going in Ukraine, but when you start talking about tactical nuclear weapons, that's a conversation we haven't had in this country since the '60s with seriousness. The World Economic Forum, the world they envision, the world you and I grew up in professionally, I think that world is gone. We're moving to something else. I use the Russian invasion of Ukraine really as an ending point or an exclamation mark on trends that we have seen percolating probably 10, 5, 3 years that accelerated extraordinarily greatly in the COVID-19 pandemic up to the war in Ukraine and the disruption that that has caused really impacts businesses, and this is going to be something, I think, we're going to have to deal with literally on an ongoing basis forward. Lots, really, to unpack there, but I do have to acknowledge you for pointing out it was really the World Economic Forum that has led, I thought, the charge for a global economy and globalization and unfortunately, I think that world is now dead. Susan Divers: I hear you and I feel the same way about the Forum. LRN participated in it quite actively until fairly recently, and the Forum really did an excellent job of helping global leaders cooperate, frame some of the rules and the practices. Maybe when the current situation resolves itself one way or another, there'll be an opportunity to do that again. But getting a little bit more granular at this point. You've written about the impact of the Ukrainian war on the supply chain and certainly for business that's one area where the rubber really hits the road. Can you explain that a bit to our listeners? Tom Fox: Sure. The Ukraine War, the Russian invasion of Ukraine, as I said, put a exclamation point on this. One of the key disruptions from COVID-19 was indeed supply chain. Here, I think for the first time, Susan, we started to look at geography as a risk. Geopolitical risk has been known for quite some time, but with the COVID-19, we have the swaths of the world that were unavailable to us because of the pandemic. As the pandemic raged through China and moved to India and moved to Africa, large parts of the global supply chain were literally shut down completely and they couldn't get back up, couldn't get running again. We saw, from COVID-19, a geographic risk that we have perhaps not considered as much before. This is different than an island that may worry about climate risk or flooding or fires in California or something like that. We had real geographic risk. The Ukraine War really put an exclamation mark on geopolitical risk. What is the risk? What was the risk in 2019 of Russia invading Ukraine? Certainly there were discussions at the highest level of our government. Frankly, I don't think you and I, wasn't on our radar. Maybe if you read foreign policy, it was on your radar, but for the business practitioner, from the compliance professional, I don't think we were thinking about a Russian invasion and what that might do to either our supply chain or business partners or customers. Well now, if the Ukrainian grain cannot be put in the global food supply chain, that's a huge disruption. The question that I thought about is what would be the effect of the disruption of the global food chain on one of our former employers, Aecom, Halliburton, businesses that you and I have both been involved with, but we don't think of as having perhaps a food risk. Nevertheless, if grain is not available, what do those types of risks mean for employees in allegedly or apparently unrelated companies? Companies have to start thinking about these kinds of things in ways that we haven't done before. I did a podcast earlier this week where someone said, "Look, the issue now is China and Taiwan." And he was absolutely right. That could be a military issue, could be a geopolitical issue. 82% of US semiconductors are made in Taiwan. That's a huge issue. Let's go back to our former employers who are now heavily invested in tech and actually use semiconductors as part of their manufacturing process. They're going to be impacted, let alone the US semiconductor industry and the US computer industry. That is something now that we have to consider. Are there any other geopolitical conflicts that could erupt, which might negatively impact our supply chains? And when I mean negatively, I mean you can't get your supplies out of those countries, whether it's a raw mineral, whether it's a extractive mineral, whatever it may be. Those types of issues now are more front and center than they ever have been. From the business perspective, Susan, supply chains, since at least the late '70s or early '80s, the primary goal was efficiency. That was generally translated to just-in-time. It was seen because of the experience in the '60s where particularly in the auto industry, you had lengthy supply chains and actually large number of parts piling up in warehouses that was deemed to be inefficient. They wanted it just before they needed it. That led to just-in-time. That led to one or two suppliers. We found that sole suppliers or sole plus one suppliers has a risk. That risk is, if they're in a geographic area that's wiped out by COVID, if they're in a geopolitical area that is no longer available to us, then we, as a company, have a problem with our supply chain. Certainly there are many industries that have been offshored outside of the United States. From our industry and service, or rather service industry folks like us, to manufacturing, to everything in between. That is now trying to be reshored on American soil. Can we do it? Yes. Can we do it tomorrow? Probably not. Can we do it in time for Christmas? Probably not. We're going to have to retrain, we're going to have to retool. We may have to allow greater immigration to get people in to do those jobs and it brings up an entire series of questions. It brings up economic questions. How much more is it going to cost to reshore? How much more does it cost and pay an American wage as opposed to a Philippine, Bangladeshi or other wage? Or you name the country outside the United States where the wages are disparate. All of those issues are now in play in a way that certainly they were percolating around and percolating along in the second half of the last decade. COVID-19 accelerated those conversations, particularly around just-in-time and sole source suppliers. But now, I don't know how much of the globe Russia consists of. I think at one point, it was 12%. That's not available to us as a supply chain partner now and Russian partners are not available to us as supply chain partners. Now, what happens if China is not available to us as a supply chain partner or Taiwan because of an armed conflict with China. How is that going to play? Or can we even get semiconductor chips out of Taiwan if they're in an armed conflict with China? All of these issues are now front and center and I think every company has to be looking at their supply chain, who's in their supply chain. Then obviously, this ties into things that were not deemed to be connected to all of these issues before, such as conflict minerals. Conflict minerals required you as a company to determine or any of the minerals you're buying, the four Ts, I think, coming out of countries primarily in Africa under conflict. This was the first time companies had really taken a deep dive, not to their direct suppliers, but to their sub-suppliers and they found out we don't exactly know who all of our sub-suppliers are. Obviously the Uyghur Forced Labor Prevention Act has huge impact on supply chains and hopefully, we can talk about that at some length in a little bit, but all of these issues on supply chain, it's elevated the discussion of the corporate supply chain, I hope, to where it properly belongs, in the board of directors level. But for the people that we deal with, the CCOs and compliance professionals, I think it should be a part of an equal conversation because what are the risks? I was going to say implications, but what are the risks of moving your supply chain, reshoring it? It's a change so the risks change. It may not be an FCPA risk because you may be in the United States, but almost every state in the US has an anti-corruption law and a state anti-corruption law. I had to look at it one time, 37 states do. That's not that you can't bribe our state government officials, every state says that, but 37 with regular commercial private or private anti-bribery laws. When was the last time you, as a compliance professional, had to assess that issue, that risk? Lots of new risks and you, as a compliance professional, need to be a part of those discussions so you can begin preparing your corporation for those eventualities. Susan Divers: Well, that's a perfect example, or I should say it's an example on steroids of how you have to respond to the risks that face you today and hopefully, tomorrow, try to look around corners. I remember, I think it was in the 2020 guidance that DOJ put out. They said that you can't let your program be a snapshot in time or go on cruise control. That's one of the biggest traps I see people fall into. You ask them what their risks are and it's kind of like what the risks were last year. With this environment and with what you just outlined in terms of supply chain, there's going to be a lot for compliance teams to do. How should people be addressing that right now? I know we'll talk later about sanctions and anti-money laundering being the new FCPA as Deputy Attorney General Monaco said recently, but what's your advice today in terms of how to think about those risks? Tom Fox: Susan, you hit it exactly on the head. Assess your risks when your business changed. You reference the 2020 update to the Evaluation of Corporate Compliance Programs. That's where the first time the Department of Justice formally said, it's not an annual risk assessment. It's not a biennial, all-encompassing $100,000 risk assessment. It's an assessment when your business changed. The beauty of the timing of that statement, it was June, 2020, everyone's risk had changed because we were working from home. It didn't mean your risk increased or decreased, they changed. How do you assess working from home or how did you assess working from home from a compliance perspective? Once you made that assessment and then you found there were actually new risks, then you had to put a risk mitigation strategy in place, then you monitored that strategy to determine its effectiveness and then you used that information to upgrade your compliance program. The formula is in place for all of these things, but it starts with exactly what you said, Susan, assess your risks if your business has changed and everyone's business has changed literally, particularly in the supply chain. You've got to know who your suppliers are. From the business perspective, who can supply us is paramount. Pricing is going to be paramount. But from the compliance perspective, where are they getting those? If you're a clothing manufacturer, how many of your suppliers are coming out of Bangladesh and how many of those suppliers are violating any sort of fair trade or human rights laws? Even what's the safety, as we know from the Plaza collapse a few years back in Bangladesh. You have to know who's in your supply chain to a level and degree that you didn't previously think about unless you were in conflict minerals. But the beauty of that is that if you make that assessment down into your sub-suppliers from your supply chain, you as a business will be stronger. You will see, number one, if there are inefficiencies in our supply chain, but two, if there's a disruption, you'll be able to mitigate that if a disruption occurs because you can move to another supplier because you know where the parts are coming in from and hopefully, you'll be able to have prior knowledge or planning around that. But think of a weather event. In 2021, I was living in Houston. It hit seven degrees. That was the first time we'd had single-digit weather in Texas since 1890. Well, we can't prepare for that, yeah! This is a town that had gone through two 500-year floods and 1,000-year flood over the past 18 months. We had a wildfire north of Houston. We'd never had a wildfire in Houston, Texas in my lifetime. All of that's to say is that things have changed. I don't pretend to say I know which way it's going, I just know that you have to be there. You have to have assessed those risks and have a plan in place if you can't utilize all the way down in your supply chain, but that gives you the opportunity to be more business efficient and if a catastrophe does occur, you're more quickly able to respond. Starts with a risk assessment, put a risk management strategy in place, monitor that strategy, and then improve your compliance program as information becomes available to you. Susan Divers:I totally agree with that, Tom and I want to relate it back a little bit to a point you raised earlier too, which is this gives you an opportunity to make sure that you're dealing with ethical sub-suppliers and that your whole supply chain meets spec. I think I've seen in the past, in my long years as an ethics and compliance lawyer, and before that as more of a specialist on FCPA that a lot of times, people don't know who their sub-suppliers are and the first they find out is when there's fraud or potential bribery issue or diversion or a theft of intellectual property. It does give you an opportunity to get a more solid grip on your suppliers and make sure that they are the right people that you're dealing with. Let's turn from that, which is I think a very good segue to the issue of economic sanctions. There's really been a quantum leap in that area, even it was starting before Russia, I think, with the sanctions on Huawei and the heating up of tension in the US-China relationship, but now it's on a completely different level and that really, I think, has to be top of list for companies when they review their ENC programs. Can you talk about that and give us some guidance? Tom Fox: Sure. Once again, Susan, let me use the Russian invasion as the exclamation mark because under the Trump administration, we saw an exponential increase in the use of trade and economic sanctions. I had several friends in that space and every once in a while, I'd email them, "Well, we had three changes today. What do you expect this afternoon?" The point being that the prior administration saw those as legitimate and important tools for US national security. That has only increased now on steroids because of the Russian invasion. What the Trump administration's use of those tools did was it elevated the discussion of the trade compliance director in a corporation to the board of director level. It may have elevated them within the compliance function or generally within the C-suite because people now had to call trade compliance and say, "Anything new today?" Well, the sanctions that have come out after the Russian invasion have been all encompassing. Now, I looked before this podcast, I think we're on our seventh round of sanctions and more to come. That's seven rounds from the United States. That doesn't even count the UK and Western Europe who have equally sanctioned Russia. Many US multinational companies are also subject to UK or EU trade sanction directives. You need to be cognizant of those. But the current trade sanctions that have been levied, and when I say there's still more to come, we haven't gotten to the nuclear option, which is secondary sanctions. If we get to secondary sanctions, that's an entire level of trade and economic sanctions literally that we have not seen since World War II. Discussion though, around trade sanctions, and once again, I've talked to several of our colleagues who have that as their specific compliance remit and their specialization is they now feel elevated within the corporation. They feel that the issues they've been dealing with, their professional careers are now being discussed literally at the board of directors level because of these huge potential fines and penalties, the huge visibility. As important as these legal restrictions are, Susan, it's actually the reputational damage. Just think about the companies that either drag their feet about leaving Russia or were slow or less than somebody's idea of we need to be out of there. They were excoriated in the press for doing business in Russia after this invasion. Those conversations have largely on by the wayside because I think most US companies are out of Russia now, but the reputational damage for the violation of trade sanctions or even some sort of norm or standard now costs more than perhaps even the finer penalty would've cost. It's really a huge change for our colleagues. It's an important change because now, those issues are being evaluated together with supply chain at the board level in a way they have not been previously evaluated. You may now need to look, you need to call your trade director of trade compliance about issues in your supply chain. You need to call your director of trade compliance about where are we doing business? How are we doing business? Who are we doing business with? Who's our customer base? Are we selling with commission sales agents, company employees or distributors? If we're using distributors, are they reselling our products into Iran? Are they reselling our products into a country that's exporting to Russia? All of those issues now, I think, are being discussed at the highest level of a company. But for me, Susan, the real beauty of this discussion is finally, I think, the silos are coming down within a corporation and you're seeing a much more holistic approach to many of these issues that we'd not seen previously. Once again, if I could go back to the DOJ's June, 2020 update to the Evaluation of Corporate Compliance Programs as presaging all of this, they said in that document compliance must have access to all data silos within a company because compliance needs to know what everyone's doing so compliance can do its job. Well, that turned out to be true, but it turned out to be true much broader. I think the DOJ was onto something when they said that, and I think now, companies are realizing you have to have this holistic approach. Trade sanctions and export control sanctions are here to stay. The other insight from the Trump administration use of them and the Biden administration use of them is they're administration agnostic. They're not going to go away and if 2024, we have a Republican administration, they are probably going to continue those and they're not going away. If there's a Democratic administration, they're not going away. They're probably going to continue those. Sanctions, trade sanctions, export control sanctions are here to stay. They're probably going to get more robust. And until Russia pulls out of Ukraine, I think companies have to take these very, very seriously, both for a potential legal finer penalty, but even more important is in the commerce or the business place of public opinion. Susan Divers: I totally agree with everything you've said and you've made a very articulate vision of what a major challenge is for compliance teams. The only thing I would add is, it's interesting to me, that this can affect small and medium-sized companies that don't think in these terms and may not even really be very sophisticated. When I was looking a couple of months ago, I came across a case involving a false eyelash manufacturer who was importing what turned out to be false eyelashes that sourced in North Korea. I mean, it was a Chinese supplier, but the sub-supplier was North Korean and they got in trouble. As you know, it doesn't really matter if you don't know. That's no defense and they paid a fine for that. It was a good reminder that trade sanctions can affect everyone and that you really, hopefully, have to have that on your radar. Let's take an interesting topic off of this, which is have the enhanced sanctions started to really impact whistleblowers? I mean, we know that FCPA enforcement has certainly inspired a lot of whistleblowers, as well as SOX and other areas such as that. But what about trade sanctions and what about AML and what we're seeing? Tom Fox: That's been, I don't want to say it was an unintended consequence, but one of the most interesting outcomes or aspects of the Russian invasion. For the first probably 30 days, the most ubiquitous picture of the Russian invasion was a yacht steaming away because it was a Russian oligarch's yacht and they were trying to steam to a port where the US couldn't come in and forfeit them because of trade sanctions and sanctions put on the Russian oligarchs. But here's what happened. On January 1st of 2021, US Congress overrode President Trump's veto of the National Defense Authorization Act. In that bill, there was something called the AML law of 2020. The AML law of 2020 was the first update to our anti-money laundering laws and trade sanctions laws since the Patriot Act passed in the wake of 911. As part of that change, a bounty program for whistleblowers was put in place similar to the SEC bounty program put in place in Dodd-Frank. That Department of Treasury money laundering or anti-money laundering bounty program applies to those Russian yachts because if a yacht is seized and sold, the person who reported it can be eligible for up to 30% of the proceeds of that sale. This created an entire cottage industry of marine yacht hunters who knew and they are working with law firms to actively, and when they find one in a port that the US can get jurisdiction over, these law firms notify the DOJ and then the DOJ does whatever they need to do to try to get seizure of that yacht in a foreign country. That was viewed as hugely popular and the American public is cheering them on in a way whistleblowers have never been cheered on in our lifetimes. I remember I interviewed a woman whose law firm specializes in whistleblowing and I said sort of in an offhand manner, "Are you telling me that whistleblowing is sexy?" Her response is, "You mean, it hasn't always been that way?" No, it hadn't. But now, it was seen as directly in the interest of the United States, particularly our national security for these whistleblowers to come forward. As important as whistleblowing is to the SEC, I don't think it had ever been considered a national security issue. That ties to what the Department of Treasury has announced publicly that they expect US corporations to be in on the fight of trade and economic sanctions and money laundering by self-reporting. I had had a little trouble tying self-reporting of your own violation to the fight against national security. But what the Treasury Department argued was, come to us, tell us if you find people within your organization violating trade sanctions or economic sanctions and we'll give you credit for that, that may be a declination up to it, including a declination. The DOT has truly tried to incentivize companies to be a part of this fight and that is now the same for whistleblowing. Whistleblowers are now seen. There's one other document called US Strategy on Combating Corruption, which came out in December, 2021. In that document, the Biden administration pointed to whistleblowers as a component of the fight against bribery and corruption, which that document elevated to national security status. Now, we have whistleblowers who before the Russian invasion, certainly were a part of the legal landscape and part of the compliance landscape, but now they're being told, you are a part of our national security interest and you are a part of our national security fight and if you bring us this information in the form of blowing the whistle, you will be rewarded. The US public is saying, you go. You go find those yachts. You go find those people who are doing business with those that are not in the national security interest of the United States and we'll support that. That's, in my mind, just a huge psychological change. Susan, I know you have written and said more about whistleblowing and how to treat whistleblowers than about anybody and I know this is something that you've been talking about for a long, long time, but I really see this as a true shift in the way whistleblowers are thought of in the United States. Susan Divers: Well, I'm glad you brought that point out because I think that's true. Tying it furthermore to the impact of corruption on national security, I think is an idea whose time has come and we're going to do a whole other podcast on that as part of this series so I won't get into it a lot. But the concept of corruption as a victimless crime has been around as long as I've been practicing, which is a long time. It's not a victimless crime. I don't need to convince you. But it basically corrodes good governance, it corrodes social structures, it makes it harder for the poor. I mean, if I can go bribe my way, get a MRI ahead of everybody else in some less developed country, I'm jeopardizing the other people who can't afford that in that country and I'm also corroding ethics and good governance, but it hasn't been seen that way in the past, either by the government really or in the corporate community, and so we'll get into that more in the next podcast. But that's fascinating to tie the whistleblowing into that and it has the additional benefit of being true, if you will. I have to say, I love the image of the yacht hunters. It's one of the first things I read when I open The Wall Street Journal in the morning to see if there's some oligarch's yacht that's being towed away or whatever, but it's definitely an idea whose time has come. Tom Fox: For those of you who think our ever new ideas, I think if you look back in history, that was called piracy and or rading by English- Susan Divers: Letters of marque. Tom Fox: Yes, exactly. Letters of marque. It's an old concept, but it's equally valid today. Susan Divers: Well, let's close off this session because we're going to do another podcast and talk more about anti-corruption and sustainability. But one of the things I was curious about is how does all of this tie in to the level of transparency that we're seeing in international trade, in commerce? Our chairman of the board, Dov Seidman, whom I know you know of and know has written a lot in the past about radical transparency and how does that tie in to what we've been talking about? Tom Fox: Susan, let me go back to 2015 and the Volkswagen emission testing scandal. I read a speech by the head of the German Manufacturer's Council, so the German trade group for manufacturers. In that speech he said, "The answer is compliance and transparency." One, be in compliance, but two, be transparent about it. That is how we, as a German industry, will get through this. Volkswagen has done what they've done. We can't stop that or do anything about that, but we, the rest of German manufacturing, can be in compliance and can be transparent about that compliance. That really struck me at the time and it stuck with me since then. The transparency, the radical transparency that Dov talks about is even more important in 2022 because of things like the Business Roundtable Statement on the Purpose of a Corporation. How many stakeholders are there now? Previously, there have been only shareholders, but now you have multiple stakeholders. It can be your employees, it can be your third parties. It can be those localities where you do business and that's where that radical transparency is so critical because they may not own shares and they may not be able to vote, but they can vote with their pocketbook. The radical transparency allows you to demonstrate to stakeholders who are going to vote with their pocketbook that we do business ethically and we are in compliance, and that you can and should do business with us because our values are what your values are. That's, to me, the power of radical transparency and it's the ability to demonstrate to those who are not regulators. Because remember, if you're fined for a regulatory violation, that's seen as a below the line sunk cost. Just the cost of doing business. Tell me how much my fine is and I can reserve for it, whatever it is. What I cannot reserve for is if 5, 10, 25 or 50% of my customer base chooses not to buy my products because I've been found to have violated sanctions or I've been found to have used Uyghur labor in product site sourced out of China, or you name the issue. That's not a bottom line cost. That's a top of the line cost. That's a cost you can never get back because you can't reserve for non-sales. It's a cost you can't anticipate, you can't reserve for, you can't mitigate the risk because once you don't have sales, you don't have sales. To me, that concept of transparency, that concept of doing business ethically, in compliance and that concept of radical transparency all really protects you and allows you as a corporation to say, "This is what we stand for. This is why we're proud to sell a product to you and hopefully, you're proud to buy a product from us." Susan Divers: Well, you're right and that really tees up the heart of sustainability. Sustainability isn't one giant checklist after another. It's what are we really doing and how are we doing it? What you're also saying too is, and it ties with things Dov said in the past, that we live in an age of radical transparency where anyone can go on Twitter, I guess, if they pay the $8 now or post on Facebook or Instagram or wherever and expose concerns. And with the incredible increase in sanctions and money laundering controls, it's just a further reason, if anyone needed one, why you have to get your house in order and you have to make sure that you are dealing with those risks effectively and of course, walk the walk as well as talk the talk. We are running out of time, unfortunately, but I'm excited to mention again that we're going to continue this conversation in an upcoming podcast. It's been such a pleasure having you today, and I know we could keep talking for another couple of hours, but we'll have further opportunities in the future. Tom Fox: I always have way too much fun when you and I sit and chit chat, whether it's over a lunch, a coffee, or a podcast, so thank you, Susan. Susan Divers: Oh, I feel the same way, Tom. My name is Susan Divers and I want to thank you all for tuning into 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 and 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.
Proceedings from a daylong symposium hosted in partnership with Florida Cancer Specialists, featuring key clinical presentations and papers in endometrial cancer. Featuring perspectives from Dr Shannon Westin, including the following topics: “Biomarker”-Guided Therapy for EC (0:00) Targeted Therapy for EC; New Directions (18:24) CME information and select publications
«Yo procuraba evitar los problemas, pero por lo general hablaba mucho y los árbitros me llamaban la atención en demasiadas ocasiones — admite Alfredo di Stéfano en su autobiografía titulada Gracias, vieja: Las memorias del mayor mito del fútbol—. Un día le dije a uno: “Pero oiga, árbitro, ¿qué... quiere? ¿Qué juegue con un esparadrapo en la boca? Así yo no puedo jugar; no puedo respirar.” Yo, cuando juego, comento el partido y voy hablando. Hablo siempre. Es mi característica.... »El peor problema era en los primeros tiempos [en que], cuando algo no entendía, le decía al árbitro: “¡Ché! ¿Qué cobrás?” [Es que] cobrar en Argentina es pitar una falta, y ellos entendían que yo les acusaba de haberse dejado sobornar. [Así que] ponían en el acta: “El jugador número nueve...” Y ¡tacatá! Multa.... »Bernabéu [—el presidente del Real Madrid—] me preguntó que qué pasaba. “Mire, don Santiago —le dije—, yo no sé por qué me anotan a mí...” Entonces averiguaron que yo decía que iba a cobrar el árbitro.... Yo le expliqué a don Santiago: “Esto es una cosa criolla. ¿Cómo me vienen a mí con estas cosas, si yo no sabía que aquí se dice pitar?” Después ya me fui acostumbrando al idioma, y todo se arregló.... »... Al final —continúa Di Stéfano—, por protestar salen los jugadores con más tarjetas que por pegar. Yo no creo que los jugadores de fútbol vayan a pegar intencionadamente para reventar a un adversario.... Eso es lance de juego. [Por lo general, los jugadores van] a buscar la pelota.... Después, indudablemente, está la picardía para buscar un penalti... pero ahora... están buscando entrar en el área para tirarse al suelo, [y] piensan más en tirarse al suelo que en buscar el gol. Y luego uno patea el penal, lo mete y se sube a la alambrera, como si hubiera hecho una gran cosa. En mis tiempos, tirarlo era una obligación. Lo marcabas y le decías al arquero: “Perdoname, pero era mi obligación.” No lo celebrabas como un gol de verdad, porque no es un gol como los otros. Es una ventaja muy grande. »Ahora es distinto todo.... Hacen un gol a los quince minutos de juego, y... [luego] hacen el sprint más grande del partido [y] se amontonan todos.... Después ¿qué pasa? Que los últimos setenta y cinco minutos de juego, si el contrario te mete dos, ¿qué vas a hacer con el gol? ... Tanto festejo, el jugador se tiene que dar cuenta de que en los partidos, hasta que el árbitro no pite el final, no tenés el triunfo asegurado. [Por eso] se dice: “No cantés victoria, aunque en el estribo estés”», concluye Di Stéfano.1 Luego de los múltiples títulos que ganó durante su carrera como jugador y como director técnico, aquel «mayor mito del fútbol» tuvo la distinción de ser presidente de honor del Real Madrid desde 2000, el año en que publicó su autobiografía, hasta 2014, el año en que el Árbitro Divino pitó el final de su vida. Y hasta el último minuto en que sonó ese pitazo final, no dejó de practicar lo que predicaba, tal y como lo expresó el Predicador de Eclesiastés: «Vale más el fin de algo que su principio. Vale más la paciencia que la arrogancia.»2 Carlos ReyUn Mensaje a la Concienciawww.conciencia.net 1 Alfredo di Stéfano (con la colaboración de Enrique Ortego y Alfredo Relaño), Gracias, vieja: Las memorias del mayor mito del fútbol (Madrid: Grupo Santillana de Ediciones, 2000), pp. 149-51. 2 Ec 7:8 (NVI)
Mac and Bone close down the week by looking at the college football teams that should have confidence this weekend, talking with Zach Gelb about what the Panthers win means and wrapping up the show with the EC shoutout.See omnystudio.com/listener for privacy information.
In this episode Jen and I look into what makes a boring boilerplate proposal go from compliant to compelling. We dig into win themes, go/no-go discussions, and so much more! Jen McGovern, CPSM, senior regional marketing manager, oversees the marketing efforts for VHB's Mid-Atlantic region. With a background as an editor and copywriter, Jen fell into the A/E/C industry in 2012 and found a passion for proposals and infrastructure projects. A prolific author and presenter, Jen is a past president of the Society for Marketing Professional Services (SMPS) Washington, DC, chapter and was named the 2022 SMPS Chapter President of the Year. She also serves on the Editorial Committee for Marketer, SMPS's national journal, as well as the national Certification Committee.
EC Comics, a name that brings to mind Fredric Wertham and the coming of the Comics Code, also brings to mind some very well-done comics by the likes of Wally Wood, Harvey Kurtzman, Al Williamson, and more. IDW has just released an Artist's Edition of original EC art by Wood, Kurtzman, Williamson, Jack Davis, and … Continue reading #755 “Best of EC Stories, Artisan Edition”
Listen!!! What do you get when a married couple of 14+ years hosts a podcast about the MANY joys and struggles of black relationships and invites two childhood friends of 38+ years who come to the table to discuss life, get people talking, and get real to heal? You get Love is He Said, She Said: A Collaboration episode that you will not want to miss! Harvey and Karese Laguerre, co-hosts of the LOVE IS BLACK podcast which discusses, celebrates, and highlights black love host a crossover episode with the co-hosts of HE SAID, SHE SAID IA podcast (minus EC). Join us as we discuss exactly what is hoped to be healed when we come to the table, how Harvey and Karese met and decided on marriage, the dynamic of Molove and B's friendship and how it may impact future relationships, possible definitions of cheating, how Molove and B's friendship has impacted them and so much more. Let's get to the table to share the joy of crossing over LOVE IS BLACK and HE SAID, SHE SAID IA to let all who listen know that LOVE IS HE SAID, SHE SAID. Let's get real to heal! --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/hesaid-shesaid7/message Support this podcast: https://anchor.fm/hesaid-shesaid7/support
Chloe asks some questions about boobs, We discuss neutron advice around menopause, How to eat slower and the importance of this, Over training, & the weekend cycle of over eating Enjoy! Join the EC method here: TheECmethod.co.uk Chat to us here
Everything was going just great – what's up with the sudden resistance? Today I share part 2 of the “what, how and why” of sudden EC resistance, and how you can interpret and respond to it like a parenting pro. Get full show notes and add your comments or questions here: https://godiaperfree.com/212 Get my free easy start guide for EC https://godiaperfree.com/start Start EC with your baby today with my popular book, Go Diaper Free: https://godiaperfree.com/thebook
Securitization Insight Ep 30: EU Securitization Regulation: Due Diligence and Transparency Requirements when Purchasing non-EU SecuritizationsDavid Shearer, partner in our London office, joins host Patrick Dolan to discuss the European Commission's (EC) report on EU securitization regulation. We discuss the various interpretations of Article 5(1)(e) and how they impact the due diligence and transparency requirements under Article 7 when purchasing non-EU securitizations.Listen and subscribe to the Securitization Insight podcast on Apple Podcasts, Spotify, or your preferred podcast app.
MBA, CPA, and CFE, what do all these acronyms mean? Listen in as we sit down to discuss a day in the life of EC's CFO. We also get the chance to pick her brain and ask some everyday questions about how to better your financial position.
On this week's episode of the Police Softball Podcast | Ep. 46 East Coast Championship recap ft. Jimmy Wolters, Trini sits down with Jimmy Wolters, Head Coach of the New York Hounds, to discuss their Big Apple Classic otherwise known as the East Coast Championship. Check out the PS.com photo gallery of the ECC! https://policesoftball.smugmug.com/EC... You can listen, watch, comment and ask questions live on my YouTube or Facebook. http://www.youtube.com/c/TriniTrinidad https://www.facebook.com/TriniTrinidad11 The best way to stay up to date with the Police Softball Podcast is to subscribe and turn on all notifications on my YouTube channel! You can also find Trini on social media: Instagram: @trinitrinidad__ Facebook: @TriniTrinidad11 TikTok: @trinitrinidad11 Check out the Police Softball Podcast Twitter at @Police_Softball! You can listen anytime on Apple Podcast, iHeart Radio, Spotify, Stitcher, Law Enforcement Today, Pocket Casts, TuneIn and Overcast!
On this episode my buddy Martel joins me as we chat about an episode from season 6 starring Corey Feldman, The Assassin!If you like wax melts and smell good stuff! Check out our sponsor at https://www.etsy.com/listing/1214448022/spooky-soy-wax-melt-box-set-highly and use code TFTP20 for 20% offCheck out House of Mysterious Secrets @ HouseofMysteriousSecrets.com and use our discount code 4130 to save 10% on some awesome horror merch now!!!https://instagram.com/tales_from_the_podcasthttps://twitter.com/TalesFromThePodhttps://facebook.com/groups/talesftalesfromthepodcast.comromthepodcastAnd can contact me through my and email us here at firstname.lastname@example.org
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.
Full episode at patreon.com/thicklinespod. Tales From The Crypt scholar Sam Szabo stretches out on the couch with Sally to talk EC's post-Comics Code title, "Psychoanalysis," a truly troubling 4-issue run. Topics discussed include: MAD Magazine, Sex and The City, real-life Jughead hats, and more. Catch Szabo skulking around Short Run Seattle Comix & Arts Festival on November 5th! Read Sam's comics at brainboogerindustries.bigcartel.com and preview her upcoming book at patreon.com/brainbooger. Support Thick Lines at patreon.com/thicklinespod and follow us on Instagram @thicklinespod.
After several years of negotiation following the invalidation of the Privacy Shield by the European Court of Justice (CJEU), on October 7, the president signed an Executive Order, and the attorney general issued regulations, implementing the agreement between the U.S. and the EU announced earlier this year to replace the Privacy Shield framework. The European Commission (EC) has issued a statement that these actions will “address the concerns raised by the Court of Justice of the European Union in the Schrems II decision.” The EC is expected to make this framework the basis of an adequacy finding that the U.S. provides privacy protections that are essentially equivalent to European law.
Join the He Said, She Said IA crew as they come to the table to discuss "The R Word." What does Reciprocity mean to you and have you seen it, or currently see it from those who you are dating? Should it be expected? Can reciprocity be conditional, or even delayed? Listen in as B, Molove, and EC tackle the "R Word," in dating and make sure you come to the table to get real to heal and start talking. Hear what words Molove says to B to have him "glowing" within the first few minutes of the show and learn the new comeback when you hear, "All men/women are dogs." Then learn and discuss the term, "Negativity Bias," and how it can affect men during the dating season and life. The squad also discusses two key things that women can do to set themselves apart from the others in the dating game. Finally, tune in to hear if someone made history with Molove and if she was led to actually paid for a date that was not on his birthday?? This will be good! LISTEN!!! We are continuing to get to the table to get real to heal and get y'all talking. Please don't forget to rate, review, subscribe and share. We appreciate you all! #letsgetrealtoheal #letsgetrealtohealanddobetter --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/hesaid-shesaid7/message Support this podcast: https://anchor.fm/hesaid-shesaid7/support
Best-selling author Melissa Ambrosini joins me again to share her journey through conception, pregnancy, post-partum & introduction to motherhood. We dive into all the things together and talk about her exciting new course, Wholy Mama and how it came into existence! Get full show notes and add your comments or questions here: https://godiaperfree.com/211 Get my free easy start guide for EC https://godiaperfree.com/start Start EC with your baby today with my popular book, Go Diaper Free: https://godiaperfree.com/thebook
Lots of topics covered today including: - Climate friendly diets - what changes make the biggest difference? - Cravings - what do they mean? - CBD evidence - Food waste - Breast feeding calorie needs - Social occasions while dieting - Social norms Join the EC method here: TheECmethod.co.uk Message us on IG here: @MadeletChloe @ESGfitness
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.
This week, Meg and Myra chats with Cristal Victoria to discuss goal setting and planning out your goals! We wrap up the show discussing new Erin Condren x Melissa Hoby planners in Target stores, Plum Paper custome stickers, EC holiday gift guide, Makse Life release, Go Wild D.C, and halloween movie reviews. Keep up with Cristal HERE! Want to join in on our next live show? Head over to our Patreon to view the tiers that is best for you and join today! JOIN HERE! Check our our first sticker collaboration with KrissyAnne Designs here at https://www.krissyanne.com/product-p/kad08856s.htm ! Available now! Grab your Go Wild 2023 ticker here https://www.wildforplanners.com/go-wild-2023 ! Follow us on IG: @plannersandwine Business inquiries: email@example.com Thank you to the sponsors of this episode Wild for Planners and Anchor. For more info, head to Plannersandwine.com ! --- Send in a voice message: https://anchor.fm/planners-and-wine/message
We are almost halfway through the season…check out this episode as EC team breaks down the good and bad so far this season… Players discussed in this episode -Christian McCaffrey -OBJ -Robbie Anderson -DeAndre Hopkins -Kyler Murray -Dameon Pierce -Jonathan Taylor -Montez Sweat -Desean Jackson -Hollywood Brown -Mark Andrews
EC is joined by Ei8ht, an Ex radio host, now a Commercial Lender with deep roots in the hip hop culture. The guys go into a conversation about the importance of owning real estate and what it takes to have a progressive mindset in life. In addition Ei8ht shares some of his own experience in the music industry. Tap in!About Ei8htOnce known for being featured on major media outlets such as; Forbes, USA Today, TMZ, MediaTakeOut, BET, and MTV for his work as the lead host on the highly publicized radio show Street Disciplez Radio, author and entrepreneur Tarik "Ei8ht" Turner partnered up with a few private investors and launched his own real estate investment lending firm Ei8ht Street Funding. After a not so smooth transition into real estate, and fears of losing it all, Ei8ht Street Funding was recently named one of the top 101 Real Estate Companies in New Jersey by Estate Innovations, and one of the 13 Best Commercial Lending Startup Companies by Beststartups.usFollow Ei8htBiz Site: Ei8ht Street FundingEi8ht Site: Ei8ht.orgIG: @ei8htstreetfundingFB: Ei8ht Street FundingEmail Lorita@ei8htstreetfunding.comLike the pod? Subscribe and follow:IG: @hhcloverleafSite: hiphopcloverleaf.com
Listen!!!!!! The He Said, She Said IA Podcast crew of B, EC, and Molove are back at the table with different perspectives discussing life....AFTER DARK!!! Start the episode by hearing the answer to the question, "How Close Is Too Close?" Check out how Molove completes her mini-screens now, then, find out whether or not be feels some type of way about the "courtesy check." Is Molove being too nice, or does it matter if a person you are dating may be connected to someone you may encounter at special events? EC also weighs in and does he agree with B, or, is he rocking with Molove this go around? Move on with the crew to discuss whether or not men, and women, can desire only one of each other, or nah. Also, is the desire conditional? During this conversation, the crew revisits FWB's and they also discuss Post Traumatic Slave Syndrome (PTSS) and it's possible affect on the Americanized Black Community. Is it too deep, or something that people should take into consideration? Are we adhering too much to society's norms, or, are we putting too much pressure on ourselves to conform? With conforming, the crew discusses Polygamy and Polyamory with limited views (that will be revisited with an expert/experienced person practicing this type of relationship in the hopeful near future), if marriage is just a piece of paper, and they cross the threshold to discuss their love for, but the reality of Nipsey Hussle and Lauren London's relationship. Is marriage a necessity when taking care of home and setting your loved ones up for when you are gone? When considering marriage, or life partnership, is there a different standard, or expectation, of what a woman should bring to the table vs. a man? Is there too much pressure to make it happen or not? Listen as we discuss these topics and more while coming to the table to get REAL and HEAL, then form your own opinions and have your own discussions. Remember, we want to get people talking, because communication is the key. Thank you for joining us each week to support and please rate, review, and subscribe! #letsgetrealtoheal #letsgetrealtohealanddobetter #HSSSPodcastIA #B #Molove #EC #Blackpodcastsupportnetworks --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/hesaid-shesaid7/message Support this podcast: https://anchor.fm/hesaid-shesaid7/support
Everything was going just great – what's up with the sudden resistance? Today on Ask Andrea I share part 1 of the “what, how and why” of sudden EC resistance, and how you can interpret and respond to it like a parenting pro. Get full show notes and add your comments or questions here: https://godiaperfree.com/210 Get my free easy start guide for EC https://godiaperfree.com/start Start EC with your baby today with my popular book, Go Diaper Free: https://godiaperfree.com/thebook
Tales From the Crypt is a 1972 British anthology horror film directed by Freddie Francis. The film, consisting of five segments adapted from EC comics, was produced by Amicus Productions, which made several horror anthology films throughout the 1970's. The film stars Joan Collins, Peter Cushing, and Ralph Richardson. The plot focuses on a group of 5 strangers who encounter the mysterious Crypt Keeper in the catacombs. He reveals to each of them the possible manner in which they might die, in the hopes that they might stray from their evil ways. If you have anything to add to the discussion, please don't hesitate to do so by reaching out to us on social media @TheFilmFlamers, or call our hotline and leave us a message at 972-666-7733! Watch Tales From The Crypt: https://youtu.be/z-Tdt327vaQ Out this Month: Week 1: Shooting the Flames Week 2: Tales from the Darkside Week 3: Tales from the Crypt Week 4: Top Ten Treehouse of Horror Segments Patreon: Cat's Eye Coming in November 2022: The Neverending Story Legend Top Ten Gateway Horror Patreon: Gateway Horror Poll Get in Touch: Support us on Patreon: https://www.patreon.com/TheFilmFlamers Visit our Store: https://teespring.com/stores/thefilmflamers Twitter: https://twitter.com/TheFilmFlamers TikTok: https://www.tiktok.com/@thefilmflamers Facebook: https://www.facebook.com/TheFilmFlamers/ Letterboxd: https://letterboxd.com/thefilmflamers/ Our Website: https://www.filmflamers.com Call our Hotline: 972-666-7733 Our Patrons: Ashlie Thornbury BattleBurrito Benjamin Gonzalez Bennet Hunter Brandon Anderson Brandon C CenobiteBetty Dan Alvarez Daveisruff Erica Huff Gia-Ranita Pitt GWilliamNYC Hunter C Kimberly McGuirk-Klinetobe Kyle Kavanagh Lisa Libby Loch Hightower Matthew McHenry Mr. E. Patron Nicole McDaniel Nikki (phillyenginerd) Orion Yannotti Penelope Perfecta Erecta Poodie Castle Random Dude Robert B. Sean Homrig Senor Sombra The Unknown Patron Walstrich Sweet dreams... "Welcome to Horrorland" by Kevin MacLeod (incompetech.com). Licensed under Creative Commons: By Attribution 3.0 License http://creativecommons.org/licenses/by/3.0/ Includes music by Karl Casey @ White Bat Audio
What you'll learn in this podcast episode How do you know if your ethics and compliance program is successful? How are you capturing data and comparing it to industry benchmarks, or tracking your own company's trends over time? In this episode of LRN's Principled Podcast host Emily Miner, director of Advisory Services at LRN, talks about benchmarking E&C data with her colleague Derek Clune, product manager of Data & Analytics. Listen in as the two explore how benchmarking practices come to life and the role AI plays in LRN's new Catalyst Reveal solution. Featured guest: Derek Clune Derek Clune has been working in the ethics and compliance space for over 5 years with an emphasis on data and analytics. As a Product Manager at LRN, Derek is responsible for the vision of LRN's new data and analytics platform; Catalyst Reveal. His main goal is to provide E&C professionals with more actionable data to understand their E&C program effectiveness better. Derek's team works to create products that offer best-in-class prescriptive interventions to improve E&C programs and ease the administrative burden. 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: Gone are the days of checklists, ethics, and compliance programs where one simply goes down a list of program features and elements. Now, regulators, employees, customers, leaders are asking, are our ethics and compliance programs effective? Are they successful? Well, how do you know? Hello, and welcome to another episode of LRNs Principled Podcast. I'm your host, Emily Miner, director at LRN. And today I'm joined by my colleague Derek Clune, product manager of Data and Analytics at LRN. We are going to be talking about ethics and compliance benchmarking and how organizations can track their own trends over time, as well as compare themselves to industry peers. We're going to talk about how all of this data comes together in technology environments like LRNs new Catalyst Reveal Solution which is launching soon. Derek is a real expert in this space. He's been working in that data and analytics vertical at LRN for a number of years, and is a key architect behind our product innovation and incorporating the insights of our industry collaborators at major corporations around the world. Derek, thanks so much for joining me on the Principled Podcast. Derek Clune: Absolutely, Emily. Pleasure to be here. Emily Miner: So before we get in, maybe just some definitions and level setting. So what is benchmarking? The way that we think about it, it typically means comparing what you do as an organization to a number of comparable organizations or individuals. And usually this is done in a quantitative way, so a more kind of a numeric databased way as opposed to a qualitative way. And benchmarking is helpful just for comparative purposes. And it can also help to identify best practices in the industry. And best practices referring to those behaviors, those practices systems, which some sort of research shows that the very top firms use in a way maybe beyond or to a greater degree than other organizations. So why do organizations benchmark or want to benchmark? Derek, I know that you have a lot of conversations with our client partners around their benchmarking requests and their needs. But sort of as an overarching point, why are companies interested in benchmarking? What's the value to them? Derek Clune: Yeah, I think there's a number of reasons why we see it. In my conversations with our partners, obviously regulators are looking at ethics and compliance programs with much higher scrutiny than they ever have. And so organizations want better visibility into the wider space, whether that's how their ethics and compliance program measures against others within their industry, whether that's how it measures against others from an employee size or geographic footprint. So organizations use really two sets of benchmarks, internal company benchmarks. Their own data and organizational assessments and benchmarking those quarterly year over year to measure their own program. But also they want a broader audience to compare themselves to, to really see where they... For lack of a better term, rank within the pack so to speak. And so a lot of this we see is all around measuring ethics and compliance program effectiveness. How do I know my program's effective? I have the parts and the components, the codes of conduct, the policies, the disclosure certifications, but how do I know that those are effective? And we're seeing more and more that data is being used as a key component in that measurement of program effectiveness. Emily Miner: Yeah, I'm reflecting on some conversations that I've had with our partners where they've said, our calls to our hotline are X percent. Is that good? When we look at our... We can collect data on ourselves and measure it and certainly that's sort of where organizations have been heading for a while. This increased data collection and analysis. But sometimes doing that in a vacuum, you're sort of left wondering, okay, well, the number is four, is that good? Should it be five? Should it be one? Should it be 20? What does this mean? And I think that's where that comparison is helpful because you used the term kind of broadening the pool or broadening the lens. I don't remember exactly what you said, but that idea of broadening your view finder. And that's where I think the strive for this desire for being able to benchmark and compare a large place of where it comes from. And just also as humans, we like to compare ourselves to others in so many parts of our life. So there's maybe a human nature component to it too. Derek Clune: Yeah. No, absolutely, you took the words right out of my mouth. None of these organizations while they all are unique operate in a vacuum. And so they need to have some sort of comparison just to know that they're below, above or equal to a number because we know the regulators don't give specifics. So the next best thing that we have really is this benchmarking tool of, in our case all of the LRN partners, which over 2000 partners in a number of different industries, Fortune 500, et cetera. Emily Miner: Yeah. And so Derek, I know that you partake in a lot of voice of the customer type conversations, and you are the recipient of a lot of requests for information from others within our organization. What are some of the top requests or data questions that you hear from our partners? You talked about wanting to measure program effectiveness, how are people thinking about program effectiveness? What do they want to measure? What do they currently have versus what don't they have but they want it? What are some of the general themes? Derek Clune: At a high level we know that all of these questions typically start with a risk assessment. A company will do a risk assessment from a third party to get at maybe their blind spots or to tell them some things that they already know. And so in most cases that serves as the initial roadmap of different topics to consider around benchmarking around these data questions. And so from there we see organizations typically focused on the course data. That's the most popular one. We're rolling out mandatory training, how are my employees performing on that training? It has some sort of test in it, are my employees performing better or worse than I expected or right on par with what the requirements are? And within that there's a lot of different sub context. So is a particular business unit outperforming or underperforming based on the average or the median? Is there a regional confusion around a question? So I would say the initial focus that people immediately go to is the mandatory training that is being assigned and the course performance metrics I'll say, how employees are performing within those courses. There are a lot of tertiary components that are critical to measuring program effectiveness. What we see also is culture being a critical component of ethics and compliance. And larger initiatives at an organization at measuring that overall learner sentiment of the communications and the courses that are being rolled out to the learners. So not only are we looking at the performance aspect of those but also the sentiment and learner feedback of what they think. All of those kind of surveys where you're getting additional feedback from employees is another great metric. Overall investment. Of course, senior leaders and maybe chief ethics and compliance officers, they want to see the return on investment in the ethics and compliance program. So what metrics can we look at to demonstrate that there is an ROI there? And then another piece that we see is the communication strategy and how do we take those metrics to identify the best time to roll out a campaign. Frequency of reminders, those types of things is another point at which we can look at and also improve upon year over year. Emily Miner: Yeah, that's interesting. I actually don't know the answer to this, do we do any type of AB testing? I'm kind of fascinated by that idea that you were just describing of what's the optimal time to roll out a training and the frequency of reminders. And I was actually just having a discussion with one of our colleagues about is she the type of person that kind of takes her training right away as she is. Or does she wait till the last minute, which I confess I am that type of person. So we were just talking about kind of different type of people and how their personality, their characteristics kind of inform their behavior with respect to taking training. But anyway, so I'm just sort of thinking about like okay, we have these two types of people and how can we optimize attention and what's the right cadence of reminders to get the laggards like me or the right time of year? So with that, how do we know? Do we do any type of AB testing or comparison? We tried one reminder a week last time, let's do two reminders a week. How do we kind of know? Derek Clune: Yeah. So at LRN, we currently have if a partner is using the LRN platform, we do have the overarching data of when they're sending reminders, when they're rolling out campaigns. We are just at the forefront with this new catalyst reveal dashboard of being able to look at that data and make prescriptive recommendations for organizations. And so what I've seen is a lot of there's really no one size fits all for any of these organizations and their communication strategies. You have some people who are rolling out training and communications once a year, some on a quarterly basis, some biannually. And so we're just at the forefront of being able to look at that data, look at the time of a completion, how many people completed before a due date and after a due date. And we're expecting sometime mid next year to be able to make those prescriptive recommendations. And the exciting thing about this is the more people that we get onto this tool and using the tool, the more accurately we can prescribe different methods. So potentially we could say for a specific industry like tech, we see that Friday afternoons are a better time. This is very normal in sales and kind of marketing strategies for emailing. When's the most optimal time to send an email and somebody will look at it, 11:00 AM on Tuesday is something the last time I checked. So we want to be able to do that. But also within each of those communications, what are the collateral that are the most effective? A quick short video from the CEO that Emily is going to click on, is it the email spoof to look like it's coming from the CEO? That might get everyone's attention. So there's a lot of things that we're looking at currently, and we'll be doing that sort of AB test as you mentioned. Emily Miner: Okay. Well, that's really fascinating. So it sounds like you and I should have another conversation in June or July of 2023, and you can tell us what you found with all of this. I love it. I think that's so interesting. And you're right that it's about building up that data pool, and it's only as good as the size of the data pool just like genetics testing. What percentage of me is Irish? So we talked a little bit about... You've mentioned Catalyst Reveal, and you're talking about LRNs platform. So I kind of want to turn to that now because this is a really exciting product launch for LRN. And we're launching out a whole new platform in just a few weeks in mid-October that will dramatically increase the ability for our partners to benchmark against some of those metrics that you were talking about before. And I know that you've played a lead role in designing what that looks like, and the feature functions, and how it work and making those choices. So one, can you tell us what Catalyst Reveal means? And then two, what will it enable our partners to do? Derek Clune: Sure. Yeah, so Catalyst Reveal is the name that we've given to our new data and analytics platform. We want to reveal actionable data and insights to our stakeholders who are mostly ethics and compliance program administrators, who are really in the day to day nitty gritty of an ethics and compliance program and the data around that itself. Secondly, chief ethics and compliance officers, thirdly our leadership board of directors, et cetera. So the name reveal comes from the idea that we want to provide our partners with more actionable data so that they can get deeper insights into their employee populations. But also be able to use those insights through data to take action accordingly. So that's where the reveal comes from. [inaudible 00:15:10] itself really is we've really revolutionized our data and analytics platform to allow for administrators to do a whole lot more than they ever could through LRN. Number one is the organizational aspect of the data and benchmarking just the single organization's data. So I have all the LRN employees. I want to be able to compare and contrast sales with finance, with marketing, and see how those test scores are on a quarterly basis year over year. That's something that's going to be within the tool. Additionally, as we're talking now, being able to benchmark those pieces of data to a larger LRN audience. So within a particular industry, how do we compare within an employee size of 5,000 to 10,000 organizations of that size? How do we compare with organizations with a revenue between 500 million and a billion dollars? And so going back to the beginning of our conversation, this allows our partners to internally benchmark and externally benchmark. So they have the numbers and the data, and they're not in a vacuum because they can quickly with one click of a button look at the benchmark and see how they compare. And the main aspects of our initial launch in October are going to be the course data. So the course performance metrics that I mentioned that we know organizations are keenly attuned to, the company culture and measurements around that. And finally, the overall learner sentiment on the courses themselves. In the future will continue to add but those are the three core dashboards and benchmarking capabilities that partners will be able to have come in October. Emily Miner: Yeah, just a quick note on the potential benchmark data pool because I hopped over to our director of communications to get some insight into our partner base. And we're looking at over 1000 partners from around the world with a combined 28.3 million employees, including a big chunk of the Fortune 500. So that's sort of the potential universe of comparative data that we hope our partners will have access to, so that's really exciting. Derek Clune: My eyes light up when I hear that amount of possibility with this tool because it really is the more you put in, the more you get out. And so as the product manager of the tool, we'll be adding more capabilities such as the disclosures and certification management all around that. So you can see and in the future you can see the possibilities of, okay, if we identify a risk through a disclosure or a certification and we see that employee or that region is scoring low on say the conflict of interest course and they're not disclosing anything, we could hypothetically see potential for a high risk environment. There's a lot of really exciting things, and I know we have a bullet point to talk about what the future of this tool looks like. But it's going to be a game changer for LRN and I think for our partners as well. Emily Miner: Absolutely. And thinking about the culture data, the ability to drill down into that one particular business unit or location that's scoring way below. And kind of what is raising that red flag and going in and comparing that with some of the other data that you've mentioned, more partners can collect on our platform. And kind of triangulating those and rolling out some early intervention, or refresher training, or leadership coaching, whatever it might be. But being able to have those different kind of data sources, those data feeds pulled together into one place so that you can look at them... We've been talking about in vacuums, you can look at them not in a vacuum is really exciting. I can't wait to see how our partners use it, Derek Clune: Yeah, a single source of truth to be able to start the triage process whether that's for a high risk issue, or even if it's for triaging, okay, is this specific question in the specific course too difficult? Do we need to change the wording? Okay, we've changed the wording, do we see an improvement in performance? So we want to create that tool to really track the entire kind of ethics and compliance life cycle and just make the administrators' lives a little bit easier with that single source of truth, so that they have one place design specifically for them with the appropriate metrics that we found from our 1000 plus partners. These are the metrics that are most important so that they can build world class program. Emily Miner: Yeah, so this is all really exciting. And I know that this is a kind of an area that you and I both have some personal passion around. But we would be remiss to not also acknowledge that there are limits to benchmarking and it's not a be all end all. And we should be thoughtful to guard against what's sometimes referred to as blind benchmarking. So I want to spend a little bit of time kind of talking about where benchmarking isn't helpful or what it can't do or what we shouldn't use it for. I guess just to start, you mentioned earlier one size doesn't fit all. And I think that we know that to be true and also the regulators acknowledge that as well. So the Department of Justice in their evaluation of corporate compliance programs, guidance document, talk about how one size does not fit all with respect to ethics and compliance programs and that organizations need to consider the risks. So you talked about risk assessment as well. They need to consider their specific risks, their size, their industry, their geographic footprint, their resources, et cetera, when designing and implementing their ethics and compliance programs. So because all organizations are unique, even within a given industry there are some limitations. To give a concrete example that one of our colleagues in the advisory practice, Susan Deva shared with me. We conducted a program evaluation for two companies around the same time when we were looking at their program maturity and effectiveness. Both companies happen to be in the same tech manufacturing sector and they even produced really similar products. So one might be forgiven for thinking that our evaluations and our recommendations would be structured the same. But despite these companies similarities, they had really different risk profiles. So one company was a major exporter to the Chinese tech company, Huawei, which was sanctioned by the US government in 2019. Whereas the other company had a different customer based makeup. So comparing policies and procedures around trade control for example, would not have been appropriate in this case. So that's one example of again, kind of using that term blind benchmarking. And we just have to be careful with what we're choosing to benchmark and recognize that not everything is benchmarkable or even if it is, should be benchmarked. I'm just curious kind of your thoughts around the limits of benchmarking or where we want to take it with a grain of salt. Obviously it has a lot of really positive uses that we've already talked about, but what are some of those that we need to just make sure we're kind of eyes wide open about? Derek Clune: Yeah. I think you really want to make sure you understand the benchmark itself. So if you're looking at industry, what that makeup really is, or employee size. Two organizations of 10,000 employees can be wildly different as we know. One could be in retail, one could be in manufacturing and those have completely different risks. And so when you look at the numbers associated with the benchmark, like the average test score for this harassment course in your industry is an 80% and you're at a 70%, the immediate response is well I'm below the benchmark. But those could be wildly different organizations. And so I think understanding the benchmark itself is certainly critical to when organizations are looking at this. And even when that benchmark is... As you correctly pointed out, is correctly defined, each organization is still very unique. And so I think it is a great data point to use to orient yourself and navigate from not the end all be all solution. Emily Miner: Yeah. And really by default the benchmark if it's a complete data pool benchmark, meaning it's including all the possible data points, it is by definition an average. And the average isn't always good. My beat at LRN if you will, or one of my beats is culture. And I've worked with a number of organizations in helping them to understand and evaluate their ethical culture and improve upon that ethical culture. And we typically do provide industry benchmarks related to that ethical culture data which is helpful. But I've been in a number of conversations with chief ethics and compliance officers where they say, we don't want to be average. We want to be better than average. So the benchmark is a helpful sort of orientation of where we are, but it's not something necessarily to shoot for. Maybe we want to shoot higher because our standards... What we expect is higher. Just another little example, we recently, a few months ago I guess it was, did this benchmarking effort related to codes of conduct where we evaluated I think it was nearly 150 publicly available codes of conduct from the top listed companies in the US, UK, France, and Germany. And what we found was that over 70% of the codes we assessed had a flesch Kincaid grade reading level. And that's meaning the typical sort of grade level that one would need to have in order to understand the content. Over 70% had a reading level above a 9.5, but that's actually kind of commonly accepted to be too high. What we typically want to shoot for is like an eight and a half to nine and a half. And this is a sort standard range for not just codes of conduct but for material on a company website. Like any sort of content that is being consumed by people. It's sort of a generally accepted appropriate reading level to be accessible to the majority of your audience, whatever the audience might be. So anyway in this case, we have the vast majority of codes reading at a very high reading level. But again, that's not necessarily what a company should shoot for. And in this case we would argue that they should shoot for something lower. So I think those are just... I completely agree with you, one, just understanding what is the benchmark. Is it a valid benchmark that we're comparing ourselves to? And then assuming that it is, how do we also just put that in context of our own organization, our own goals for ourselves, our internal comparisons year over year? I think that's really important. And I've had the privilege to work with a lot of companies for many years with respect to their ethical culture where we do these recurring assessments. And so we're able to track progress over time. And what I have observed over about 10 years of doing this is the industry benchmark tends to be important kind of the first time. But as companies do this the second time and the third time and the fourth time, the industry benchmark I've even seen to sort of decrease in its relevance because at this point the company is competing with itself. Well, how do we improve versus last year and the year before that and the year before that? And that's where they're setting targets. We want to increase people's willingness to speak up by X points, how do we do that? As opposed to, well, here's the benchmark and how do we shoot for it? So that's just been an interesting trend that I've observed in how the benchmark is so helpful for setting that baseline but it can be less useful, the external benchmark. The internal benchmark is always useful but the external benchmark can become less relevant. I don't want to say useful but less relevant or less informing our goals as we go on in making investments in certain areas. Derek Clune: Yeah, right. The benchmark becomes a trend internally and so you have the trend analysis. And the tool that we're building is really helping administrators identify those trends. You mentioned context is key, and you're so right there. And in talking with some of our account executives, they're very excited to get their hands on this data and share it with their partners so that they can make more better informed decisions around our recommendations as an organization to our partners. We know that these ethics and compliance professionals are busy. They are juggling multiple jobs, if you will, at once. And so our goal is just to make their lives easier and to again, prescribe best in class initiatives and actions that they can take. And so super excited to be able to take those benchmarks, take this data, and within the context of the organization in a specific environment be able to consult and add value. Emily Miner: Yeah. So Derek, to close us out let's talk about the future. Let's talk about what's next. What is on the roadmap for Catalyst Reveal? We're launching in October. It has a lot of great features and functionality and the ability to reveal insights to our partners. What comes after that? What are we adding on? Derek Clune: Yeah, so ending on a high note here, this gets me very excited. So I mentioned reveal insights provide actionable data, and I've touched on the prescriptive aspect of having the tool work for the professional. And so that's really where we're going to be focusing on in the next year and out into two, three years into the future. So what this looks like in practice is taking all of the data from the entire LRN product ecosystem, bringing it into this single source of truth so that we can... If you think of a spider web, can pull from different parts of the web whether that's a high risk disclosure, or a knowledge check score, or a unsigned policy, or if we're bringing in hotline information from a partner, a hotline call. We want to be able to have this network of an ecosystem that we can pull from different places into a single source of truth to provide that data. And then taking the next step is to prescribe specific action of, okay, this is what we've identified within the tool and the tool suggests that you should do this. And a lot of the capabilities around that is around AI and ML, artificial intelligence and machine learning. And so some of the four key aspects that we're looking at in 2023 will be natural language processing and search. So you could similar to Google, go into this tool and type a full sentence question and the tool can provide you with the answer. What's the average knowledge check score for my harassment course? And it's going to populate that answer for you instead of the click through to get to that answer. To provide quick answers to the administrator or maybe even the senior leader, or the chief ethics and compliance officer that's walking into a meeting with the board and needs to know that information quickly. So one aspect. Second aspect would be auto notifications around the data. So giving administrators the ability to kind of program the system so it works for them. Meaning if I know the average score for a course is 70% and someone's scoring 30%, I need to know that. I want to get an automatic notification that lets me know this business unit, this location, or this gift of this amount was given. I need to know that information. And so being able to have those automatic notifications and have the tool work for you is another aspect. Two more that we're working on is around the auto narratives. And so that the tool again, having the tool work for you and prescribing action. So based on the data, here are the high risk topics that we see in your organization. Based on this benchmark here within this industry are the trainings that most people are rolling out. So having auto narratives around the data that change based on your filters or the data that's coming in. And then the last piece is going to be on a forecasting. And what forecasting will allow us to do is to do some predictive analytics in terms of where we want the program to be in the future. And so we could see... If we touch back on the campaign data, we can see that okay, out of the 10 reminders we've rolled out five, you're at 30% of getting 100% completion. Here's the forecast, here's the trajectory that we expect you to get by your 10 reminders. And so being able to forecast different components of the ethics and compliance program, all of these aspects or all of these capabilities go back to those really two points that I've [inaudible 00:34:16] on providing the actionable data, having the tool work for you, and then the prescriptive part of what should you do. We've identified this, now what do we suggest that you do? And so those are all key initiatives that we have for 2023 with the overarching idea of making this tool as self-service as possible. We want admin to be able to go in here and do all this on their own. Obviously they can rely on LRN if they need to, but we want to give them the power to be able to do everything. Emily Miner: Wow. Derek, I'm struck by how valuable these types of insights are going to be for our partners and ultimately their organizations. Like what is this in service of? This is in service of helping employees around the world know what the right thing to do is in any given situation. And know how to behave in alignment with their company's values and their code and inspire principal performance. That's so exciting to hear about the future. And 2023 is not that far away, sadly this year has flown by but wow, I can't wait to hear more. Thank you so much, Derek, for coming on and sharing your insight with us and sharing about these exciting updates for our company and for all the companies that we have the honor of working with. I look forward to coming back and speaking with you and what is it about? Eight months or so, so we can hear the answers to some of these questions that we asked. Yeah. Thank you so much, Derek. Derek Clune: Yeah, likewise. I look forward to it, Emily. Emily Miner: All right. Well, my name is Emily Miner, 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 and global organizations by helping them foster winning ethical cultures rooted in sustainable values. Please visit us @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.
Stephanie Schmidt is a senior proposal coordinator in the A/E/C industry, specializing in strategic pursuit opportunities. She has worked in the industry since 2014 and has served in proposal development roles for over 5 years.Stephanie is dedicated to continuous education and professional development. She recently completed her MBA at Arizona State University and is an active member of APMP. Stephanie recently resumed her role as the Communication Director on the Board of the APMP Western Chapter and is currently taking the Dale Carnegie leadership and communications training course.Support the show
Join Molove, B, and EC after dark, for "The Aftermath" of the culmination of "Boundaries and Insecurities" Episode. How do they bridge their way back to understanding after all of the heightened passion that exploded on the air? Or, do they just sweep things under the rug and wait for the next explosion?? Of course not!! These three childhood friends are coming back to the table to get real and heal by any means necessary, even when they are free-ballin afterdark. Finish up the clarity conversation around B's situation, understand what is meant when boundaries are spoken and put in place, listen in as the squad discusses preventative maintenance in relationships and how important it is to know your partner, check out the new meaning of "dragging" partners, then see the answer to the HS|SS Squad's question, "Do you have any non-negotiables in a relationship?" After you listen in, ask yourself what your non-negotiables are. It will be quite the self-reflection. Thank you for consistently joining us as we get to the table to get real and heal! --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/hesaid-shesaid7/message Support this podcast: https://anchor.fm/hesaid-shesaid7/support
Description: Can a newborn really go potty on the toilet? I didn't think it was possible. But after hearing about Elimination Communication (EC), on a podcast, while I was pregnant with Everest, I was intrigued. I had to know more, and sank deep into the rabbit hole of all things EC. Now, eight weeks postpartum, I'm recapping what it's REALLY like. Mom to mom, tune in to hear the challenges, joys, and secrets to making EC, with a newborn, as ease-full as possible. Connect with Wirth Wellness: www.wirthwellness.org Follow me on IG Resources Mentioned In the Show: https://godiaperfree.com/ https://wearpact.com/baby/clearance Please Note the Following Disclaimer! By listening to this podcast, you understand that the topics discussed are intended, solely, for informational purposes. The information provided is not a substitute for professional medical advice, diagnosis, or treatment and should not be relied on as such. In listening to the podcast, you also agree that Wirth Wellness is not responsible for any outcomes or decisions you make, relating to any information presented on the show. --- Send in a voice message: https://anchor.fm/wirthwellnessbyerika/message
You've looked forward to this experience, but now, baby cries when you offer the potty. What is wrong? Does crying mean EC is a lost cause? Today on Ask Andrea I address the very common experience of newborns crying during pottying and offer tips to make the experience much more comfortable for baby and parent. Get full show notes and add your comments or questions here: https://godiaperfree.com/209 Get my free easy start guide for EC https://godiaperfree.com/start Start EC with your baby today with my popular book, Go Diaper Free: https://godiaperfree.com/thebook
Anthology Horror month is here for Spooktober! We open with George A. Romero's CREEPSHOW, and next week we've got Rusty Cundieff's TALES FROM THE HOOD. After that, we've got the two Amicus adaptations of EC comics, TALES FROM THE CRYPT/VAULT OF HORROR. We wrap up the month with our massive VHS ep where we rank every segment from the V/H/S films... including V/H/S 99!
Come to Chicago for lunch with Carol Tilley as we discuss how we each first learned about the Comics Code, the mostly forgotten rich kid origins of Blondie's Dagwood Bumstead, the unsettling inconsistencies she discovered while going through 200 boxes of Fredrick Wertham's papers, what those documents reveal about how he came to believe what he came to believe, what it means to research with the brain of an historian, the proper pronunciations of Potrzebie and Mxyzptlk, her efforts to track down those who wrote letters to the Senate protesting comic book censorship during the '50s (including one of the founders of the Firesign Theater), the enduring power of EC's "Judgment Day," why she believed comic book censorship would have occurred even without Wertham's input, what she thinks he'd make of today's comics, how Wertham felt about the way comic book fans felt about him, and much more.
This week, Megan and Myra discus fall plans, Erin Condren no longer being part of the EC company, Cultivae What Matters new ownership, Maske Life cover reveals on October 7th, GoWild tickets on sale, Krissyanne Designs x Planners and Wine Stickers, New EC releases, Happy planner frosted covers, and Halloween movies reviews ! Want to join in on our next live show? Head over to our Patreon to view the tiers that is best for you and join today! JOIN HERE! Be sure when you share the show on social media to use the hashtag #plannersandwine. Thanks so much for your support! Don't forget to follow the show on YOUTUBE! You can find the channel here! Check out our website Plannersandwine.com for episode info, links to our Merch, Patreon and so much more! Love reality TV as much as we do? Make sure you subscribe to the new Reality and Wine podcast feed ! Got a questions that you want us to read on our next live show ? E-mail us at firstname.lastname@example.org ! Follow us on IG: @plannersandwine Megan's IG: @megsgotaplan Myra's IG: @myraplansit Business inquiries: email@example.com Thank you to the sponsors of this episode Wild for Planners and Anchor. --- Send in a voice message: https://anchor.fm/planners-and-wine/message
RIP Coolio! On this episode EC speaks on 50 Cent's newest show, Hip Hop Homicides. In addition, YG drops newest controversial song, "How To Rob a Rapper" off his newest album, I Got Issues. Is it too soon to drop such record?Hip Hop Leaf: MCLike the pod? Subscribe and follow:Instagram: @hhcloverleafTwitter: @hhcloverleafFacebook: @hhcloverleafYouTube: Hip Hop Cloverleaf PodcastSoundcloud: Hip Hop Cloverleaf PodcastWebsite: hiphopcloverleaf.comEmail: firstname.lastname@example.orgCreditsEpisode Artwork: The Come Up Show, CC BY 2.0 , via Wikimedia CommonsPhoto was modified.Production:ECMahfuzZahidEdgar P.Jay 717Adrian Stubb
Are y'all ready for this?!? This is the episode that almost broke the microphones!!! This is the episode that may be triggering to some as voices STAY raised due to passion around the subjects at hand. Join B, Molove, and EC, at the table as they come together to finish the conversations around Boundaries and Insecurities. Finish the conversation about accountability versus punishment, how much self-awareness is truly needed, deep dive into why majority of women may get upset at their partner's answer and listen in as men reveal why most men stop sharing information with their partners. Can they not handle it, or can they not handle the fact that they ALWAYS have to ask for more? What is considered oversharing? What is considered revealing the WHOLE truth? What factors in as curiosity? Where is the line drawn between being nosey or asking accusatory questions? Do boundaries exist if they are not verbalized to your partner? And how may all of this be linked to past traumas and PTSD manifestations? Listen in and find out, then take time to discuss and decide for yourself. Let's keep coming to the table, let's keep getting real so we can heal!! #HSSSpodcastia #B #Molove #EC #Letsgetrealtoheal #Letsgetrealtohealanddobetter #boundariesandinsecurities #Finale --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/hesaid-shesaid7/message Support this podcast: https://anchor.fm/hesaid-shesaid7/support
(September 27, 2022 - Hour Two) 10:14 & 10:35pm - The Embedded Correspondents and I begin the annual tradition of selecting this year's BBQ Central Show Guest Hall of Fame members! All of us have the 5 names we would like to see get in this year. how many are in common and how many will need to be argued for? Tune into the 2nd hour to see how efficiently we get through the process and who ends up getting into this very elite group of current members! As time allows, we will also do a new round of "100% Assurity" questions with a lucky listener and the EC's BBQ Central Show Sponsors! Big Poppa Smokers Green Mountain Grills Primo Grills David Leans / DoWellness - GET FIT for $200/month) Cookin Pellets Fireboard Smithfield Pit Barrel Cooker The Butcher Shoppe - Save 10% When You Mention "The BBQ Central Show" Bub 'N Mutha's BBQ Rub Vortic Watch Company
EC with boys – is it really that different than doing EC with girls? Boys bring both unique advantages to and a need for creativity with EC. Today on Ask Andrea, I address three common situations (that actually, girls can experience, too) – touching self on the potty, touching pee in the potty, and spraying while peeing. Listen and then weigh in with your insights! Get full show notes and add your comments or questions here: https://godiaperfree.com/208 Get my free easy start guide for EC https://godiaperfree.com/start Start EC with your baby today with my popular book, Go Diaper Free: https://godiaperfree.com/thebook
Margrethe Vestager is the European commissioner for competition. Ms Vestager has been spearheading the landmark Digital Markets and Digital Services Acts aimed at regulating the global technology industry. The new rules passed the European Parliament in July and will start to be implemented in the spring. Victoria Craig sits down with Ms Vestager to ask about the commission's win against Google in one of Europe's biggest courts (which resulted in a record fine). She also explains the importance of her hallmark legislative endeavours on global competition and fairness in the big tech space. And she talks about how the EC's Important Projects of Common European Interest programme – which allows joint investments in riskier technologies – could help alleviate Europe's energy crisis. Producer: Stephen Ryan Presenter: Victoria Craig (Image: Margrethe Vestager. Credit: Google)
Jack Thursday - All the Decisions You Make Add Up (LA 1855) Transcript: Steven Jack Butala: Steve and Jill here. Jill DeWit: Hello. Steven Jack Butala: Welcome to the Land Academy Show. Entertaining land investment talk. I'm Steven Jack Butala. Jill DeWit: And I'm Jill DeWit. Broadcasting from the valley of the cheese curds. I first- Steven Jack Butala: Burned Wisconsin. Jill DeWit: I first learned about cheese curds in Seattle. Now why Seattle has good cheese curds? I don't know, maybe a lot of people from cheese areas like Wisconsin have relocated to Seattle. If you know The 5 Point Cafe, that's the first time I experienced them. And then I have to say here in Wisconsin, now I found some even better cheese curds. So sorry, Seattle. They rock here. Steven Jack Butala: Maybe it's because the weather's the same. Jill DeWit: That's it. Wisconsin people can move to Seattle because they can handle it. That actually makes sense. Steven Jack Butala: This is a personal note. I don't know why you need to deep fried cheese. It's already good enough. Jill DeWit: It's really good. I know. Steven Jack Butala: It really kind of wrecks the taste. Jill DeWit: I know, but you know what? And then it's breaded and there's maybe beer in there a little bit? I don't know. There's just- Steven Jack Butala: They're not bad. Jill DeWit: They're super good. And you know what's great? When you get good ones, you know they're good ones. They're not all tater tot shaped. You know they're real. And so thank you. I love them. Steven Jack Butala: Today's topic, all the decisions you make, add up. Before we get into it, let's take a question posted by one of our members on the landinvestors.com online community. It's free. Don't forget to subscribe on the Land Academy YouTube channel and comment on the shows you like. It actually helps us create content that's similar to what you like. Jill DeWit: Cool. Will wrote, "Has anyone funded a deal as a JV? Anyone that has..." Excuse me. "... funded a deal as a joint venture, were you listed on the deed? And is anyone willing to share a sample or template of the agreement you used?" I will. Steven Jack Butala: It sounds out too well. Jill DeWit: Yeah. It's on landfunding.com. And it's on landinvestors.com. So if you want to go and see my sweet little EC two page agreement... And that's just a starting place. That's kind of what we use. I mean, it really is what we use. But if you want to change it up like, "Can we do this? Can we do that? Can I change this? Can I change that? I'm going to put in some money and then I'm going to do this. And then you put in money, you do that. And here's the percentages now because of this." It's all negotiable. Steven Jack Butala: A contract is an agreement between two people and the content of that agreement and the provisions and all of that stuff is what you both decide on and sign and date. That's it. If you've ever taken a law class or basic law class, they'll teach you that. Or if you've ever spoken with a good attorney, usually with the drink in hand they'll tell you that. Why- Jill DeWit: Is that what makes him a good attorney? Steven Jack Butala: Yes. In my mind. Jill DeWit: Okay. Steven Jack Butala: What gets confusing about this, especially in real estate is because we are so brainwashed by the National Association of Realtors that... And the state departments of real estate where we are, whatever state you're doing deals in. And real estate agents have no idea. They just do stuff that the person in the cubicle that sits next to them does- Jill DeWit: Told them to do. Steven Jack Butala: ... or their broker. So you end up that way with a two inch thick document that allows you, air quotes, to buy a piece of real estate. And none of that's necessary. And so contracts for joint ventures... People who do joint ventures like us are a little bit more intelligent about it. And so we know that a one or two page contract that spells out what's going to...