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A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance which is centered on your consumers. In other words, it helps a compliance practitioner to anticipate all the aspects of your employees needs around compliance. This is especially true when compliance is either perceived as something that comes out of the home office or is perceived as the “Land of No.” A 360-degree view of compliance gives you the opportunity to build a new brand image for your compliance program. This is important as the 2020 Update mandates that for a compliance program to be effective, it must be understood by a wide variety of stakeholders. Communications is often thought of as a two-way street, upward and downward, inbound and outbound, or side-to-side. However, it is better to think of it as a 360-degree effort. You simply can no longer effectively communicate in just two ways. You now communicate in a more holistic manner, and in multiple ways. If you are just thinking about communications in the classic form, you are missing something that is happening around you. The best example I can provide to you is a story told to me by Louis Sapirman, Vice President and Chief Ethics and Compliance Officer at Panasonic Corporation of North America – Panasonic USA. This story happened to him in Argentina when he was the CCO at Dun & Bradstreet (D&B). Argentina has an interesting form of illegal conduct, which is an open black market for the changing of currency. Sapirman was with a colleague who was one of the leaders from the company’s South American operations and they went into a convenience store. The person who was going to sell him the product suggested that he go just around the corner and change money on the black market where he could get a much better exchange rate, almost a 100 percent difference in the exchange rate; he declined to do so. Sapirman paid and received the established bank rate in the small transaction. He had not considered role modeling that compliance. About six months later one of his team members was in Mexico speaking to the leader of the D&B operation there. The non-compliance function employee said that he was the person who had been with Sapirman. He recounted the story of doing the right thing, when literally no one was watching. That is the power of 360-degrees in communication. Three key takeaways: Remember the definition of 360-degrees of communication. It is an effort that moves the compliance identity into a holistic approach so compliance is in touch and visible to your employees at all times What is your objective? What are you trying to do with your 360-degrees of communications and how are you using that mechanism to deliver the objectives of your compliance program? Evaluate. You need to evaluate three factors: 1) has the message been delivered; 2) has it been heard; and 3) is it being implemented?
One of the ways that CCOs and compliance practitioners can better use 360-degrees of communication is through Twitter. In a MIT Sloan Management Review article, entitled “How Twitter Users Can Generate Better Ideas”, authors Salvatore Parise, Eoin Whelan and Steve Todd found “employees with a diverse Twitter network – one that exposes them to people and ideas they don’t already know – tend to generate better ideas.” Their research led them to three interesting findings: 1) Employees who used Twitter had better ideas than those who did not do so; 2) There was a link between the amount of diversity in employees’ twitter networks and the quality of their ideas; and 3) Twitter users who combined idea scouting and idea connecting were the most innovative. Their research certainly confirms the experience of Louis Sapirman, during his time as CCO at Dun & Bradstreet. The key concept for the compliance profession is the roles of Idea Scout and Idea Connector. An “idea scout is an employee who looks outside the organization to bring in new ideas. An idea connector, is someone who can assimilate the external ideas and find opportunities within the organization to implement these new concepts.” It is the ability to identify, assimilate and exploit new compliance ideas, which makes this concept so powerful. However, to improve your compliance innovation, “you need to maintain a diverse network while also developing your assimilation and exploitation skills.” Twitter can be powerful tool for the compliance practitioner. It is one of the only tools that can work both inbound for you to obtain information and insight and in an outbound manner as well; where you are able to communicate with your compliance customer base, your employees. You should work to incorporate one or more of the techniques to help you burn compliance into the DNA fabric of your organization. Three key takeaways: Twitter can be powerful tool for the compliance practitioner. Data mine twitter for not only best practices but see what the regulators may be saying. Curiosity may have killed the cat, but it makes for a far better and more effective compliance practitioner.
How does one company and one CCO actively use social media to make the company’s compliance culture more effective? The company was Dun & Bradstreet, Inc. (D&B) and its then CCO, Louis Sapirman, who discussed D&B’s integration of social media into compliance with me. These tools can go a long way towards enhancing your compliance program going forward. Recall the declination to prosecute that Morgan Stanley received from the DOJ, when one of its managing directors had engaged in FCPA violations. One of the reasons cited by the DOJ was 35 email compliance reminders sent over seven years, which served to bolster the annual FCPA training the recalcitrant managing director received. You can use your archived social media communications as evidence that you have continually communicated your company’s expectations around compliance. It is equally important that these expectations are documented. Finally, never forget the social part of social media. Social media is a two-way communication. Not only are you setting out expectations but also these tools allow you to receive back communications from your employees. The D&B experience around the name change for its Code of Conduct is but one example. You can also see that if you have several concerns expressed it could alert you earlier to begin some detection and move towards prevention in your compliance program. Three key takeaways: How does 360 degrees of communication work in compliance? Focus on the ‘social’ part of social media. Use internal corporate social media to have a conversation.
As we move to our first non-PG podcast and channel our inner Chauncy Gardner with signature line, “I like to watch”, Tom and Jay continue to brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week. What is monitoring and oversight? Matt Kelly draws compliance inspiration from Jerry Falwell who (allegedly) likes to watch his wife having sex with another man. What is risk-based due diligence? Financial regulators opine. Mengqi Sun in the WSJ. Bank/government partnership to fight financial crime. Dylan Tokar in WSJ. Why fraud matters, the Steve Bannon indictment. Mike Volkov. Why does the Palantir S-1 appear to be like the children of Lake Wobegon — stronger, better-looking, and above average? Francine McKenna explains on The Dig. Lucenda Shen sees a flag-waving, in Term Sheet. How bad was the sexual harassment on the Washington Football Club? Very Bad. Expose in the Washington Post. Are we losing the war on AML? Martin Woods says yes. More on McDonald’s suit against its former CEO? Fenwick West lawyers. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance. In Part 2, we discussed the qualities of a successful CCO. In Part 3, communication as a driver of compliance. In this month’s final episode Part 4, Sapirman takes a look at the CCO role down the road. On Compliance and Coronavirus we had a week of Exiger. Tuesday had Brandon Daniels on Data Management and Data Security Moving out of Covid-19, Michael Beber on on M&A, IPOs and SPACs During and After Covid-19; and Anna Osborn on managed services and outsourced compliance. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday- BOD and succession planning; Tuesday-incorporating compliance strategy into long-term BOD planning; Wednesday-areas of BOD inquiry into compliance; Thursday- special guest Vin DiCianni on 3 specific BOD inquiries on compliance; and Friday-20 questions. The month of August is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. Please join us in September where I take a deep dive into Internal Controls. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here. There’s a place where True Crime meets Compliance, and its name is Fraud Eats Strategy. Check out this new show by Scott Moritz of FTI consulting, and catch all the episodes, notes, resources and more on the Compliance Podcast Network! We’d love to hear what you think of the show, and we’d love it even more if you shared it with a friend, colleague or that one guy you think might be a secret oligarch. Check out this great new podcast series here. This week on the FCPA Compliance Report, some of the top commentators in compliance have joined Tom to discuss some of the top developments in compliance over the past 10 years. The schedule for this week is as follows: Monday, Aug. 24 – Episode 495 - Mike Volkov on changes in FCPA enforcement; Tuesday, Aug. 25 - Episode 496 - Matt Kelly on changes in compliance from the business journalist perspective; Wednesday, Aug. 26 - Episode 497 - Jonathan Armstrong in changes in data protection/data privacy compliance; Thursday, Aug. 27 - Episode 498 - Jay Rosen in changes to proactive monitoring from the business development perspective; and Friday, Aug. 28 - Episode 499 - Jonathan Marks on how changes in internal audit both mirror and even foreshadow some of the changes he has seen in compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Louis Sapirman, Vice President, Chief Ethics & Compliance Officer and Chief Compliance Counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corporation. He oversees the company's regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic's longstanding values in their work. Louis previously served as Associate General Counsel & Chief Compliance Officer for the Dun & Bradstreet Corporation. During his tenure as CCO, the company was recognized as one of the World's Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms including Wilmer Cutler Pickering Hale & Dorr and Buchanan Ingersoll. Throughout his career, Louis has been recognized for his work. In both 2015 and 2016, the Ethisphere Institute named him to their list of Attorneys Who Matter in Compliance and Ethics, and in 2010 he was named International Employment Lawyer of the Year by the Association of Corporate Counsel. In this final episode, going forward Sapirman says it will all be about the data, data and more data and the metrics to go along with it. However, it is not enough to simply track data, both from the government's perspective and from the business case, your business unit folks need actionable insights. There will be greater scrutiny of both CSR and the Supply Chain and that 3rd party compliance is not just about due diligence on your suppliers and finally the role of procurement in compliance. Sapirman believes there will be more professional in the field of compliance with schools having Ethics & Compliance. Compliance professionals will be more challenged with privacy issues, trade control challenges and economic sanctions as well the cultural realities of movements such as #MeToo and Black Lives Matter. We concluded with thoughts on the convergence of compliance and risk – the importance of compliance professionals understanding their position in an organization's risk universe. Learn more about your ad choices. Visit megaphone.fm/adchoices
As the Trump Administration backtracks from its avowed goal to destroy the USPS, Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week. 1. First DOJ Opinion Release in 6 years. What is the significance? Tom explains it all in the FCPA Compliance and Ethics Blog. 2. FCPA enforcement action involving international adoptions. Harry Cassin in the FCPA Blog. 3. Bank/government partnership to fight financial crime. Dylan Tokar in WSJ Risk and Compliance Journal. 4. Once a cheater, always a cheater? Daimler pays $2bn fine. Aaron Nicodemus in Compliance Week(sub req’d) 5. At the one year anniversary of the Business Roundtable’s Statement on the Purpose of a Corporation, Mike Volkov reviews Board performance in a 4-part series on Corruption, Crime and Compliance. Part 1, Accountability. Part 2, diversity. Part 3, challenges for Board decision-making. Part 4, steps to advance corp governance. 6. Is ‘Failure to Prevent’ the next big crime in the UK? Cordery Compliance alert. 7. When can you use a corruption defense in litigation? VE lawyers in the State Bar of Texas Int’l Law Journal. 8. Does the McDonald’s suit against its former CEO implicate D&O coverage? Kevin LaCroix opines in the D&O Diary. 9. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance. In Part 2, we discussed the qualities of a successful CCO. In this week’s Part 3, communication as a driver of compliance. 10. On Compliance and Coronavirus we had a week of AMI. Tuesday had Eric Feldman discussing culture and compliance during Covid-19, Vin DiCianni on using compliance ambassadors during Covid; and Deb Waugh on challenges in the health care profession. 11. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday-what leads to a successful BOD investigation; Tuesday- Board metrics for compliance;Wednesday-BOD failures with special guest Vin Dicianni; Thursday- BOD & doing business in China; and Friday-the Board’s role in hiring. The month of August is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. 12. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here. 13. Join Tom and Vince Walden (host of The Walden Pond) for a webinar on the ROI of Compliance, Tuesday August 25, 10 AM CT. Registration and Information here. 14. Join Tom and AMI’s Don Stern for a review of the 2020 Update to the Evaluation of Corporate Compliance Programs as a part of Navex Global’s quarterly MasterClass on Thursday, August 27. Information and registration here. 15. Join K2 Intelligence FIN’s Bernard Factor for a webinar entitled “Examining the Nuances of Correspondent Banking to Address BSA/AML Compliance Risk”. Registation and Information here. 16. Join Tom next week on the FCPA Compliance Report, as he leads up to the 500th episode. All next week some of the top commentators in compliance will join Tom to discuss some of the top developments in compliance over the past 8 year. It is all leading up to the 500th anniversary episode which will run Monday, August 31. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Louis Sapirman, Vice President, Chief Ethics & Compliance Officer and Chief Compliance Counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corporation. He oversees the company's regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic's longstanding values in their work. Louis previously served as Associate General Counsel & Chief Compliance Officer for the Dun & Bradstreet Corporation. During his tenure as CCO, the company was recognized as one of the World's Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms including Wilmer Cutler Pickering Hale & Dorr and Buchanan Ingersoll. Throughout his career, Louis has been recognized for his work. In both 2015 and 2016, the Ethisphere Institute named him to their list of Attorneys Who Matter in Compliance and Ethics, and in 2010 he was named International Employment Lawyer of the Year by the Association of Corporate Counsel. In this Episode 3, Sapirman discusses how communications can be used to help drive a more ethical culture. Sapirman believes that communication as a driver of culture. But more than simply being a great communicator, a compliance practitioner must use skill to help others communicate the messages of ethics and compliance. He discusses the concept of 360-degree communications. He is a big fan of social media and the power of non-verbal communications. He concludes with an example of how he used training as an effective tool of communications. Learn more about your ad choices. Visit megaphone.fm/adchoices
Tom and Jay brave the surge in Covid cases by staying safe at home. They are back to look at top compliance articles and stories which caught their eye this week. World Acceptance bribed with bags of cash. Mike Volkov in Crime Corruption & Compliance. Implications from the end of Privacy Shield. Lawyers from Debevoise & Plimpton in NYU’s Compliance and Enforcement blog. NRA shoots itself in foot over non-compliance? Kyle Brausser in Compliance Week. (sub req’d) Using lessons learned. Jeff Kaplan and Rebecca Walker in CCI. Dick Cassin asks ‘are agents ever legal under the FCPA?’ in the FCPA Blog. Applying 2020 Updates to anti-trust compliance. Matt Kelly writing in Navex Global’s Ethics and Compliance Matters. What is a metric’s inventory and why do you need one? Tom explains in the FCPA Complaince and Ethics Blog. Follow on corruption litigation is expensive. Kevin LaCroix in the D&O Diary. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance. In this week’s Part 2, we discussed the qualities of a successful CCO. On Compliance and Coronavirus this week, we had John Fanning discusses the increased need for due diligence during Covid-19, Andy Goldstrom on compliance adaptations during Covid; and Jed Gardner on business as usual. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on the role of the Board in compliance. This week saw the following offerings: Monday-BOD’s inquiring up and down; Tuesday- the BOD’s role in internal controls; Wednesday-BOD as an internal control; Thursday- BOD governance and risk oversight; and Friday-what is your Board’s investigative protocol. The month of August is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Louis Sapirman, Vice President, Chief Ethics & Compliance Officer and Chief Compliance Counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corporation. He oversees the company's regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic's longstanding values in their work. Louis previously served as Associate General Counsel & Chief Compliance Officer for the Dun & Bradstreet Corporation. During his tenure as CCO, the company was recognized as one of the World's Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms including Wilmer Cutler Pickering Hale & Dorr and Buchanan Ingersoll. Throughout his career, Louis has been recognized for his work. In both 2015 and 2016, the Ethisphere Institute named him to their list of Attorneys Who Matter in Compliance and Ethics, and in 2010 he was named International Employment Lawyer of the Year by the Association of Corporate Counsel. In this Episode 2, we explore the qualities of thesuccessful CECO. Some of the key leadership attributes Sapirman sees as critical are Great Communication, a skill that should be practiced constantly, to ensure you remain successful. You should engage in Servant Leadership and your success lies solely in the success of others. Why you need to be flexible and even be a Chameleon. You must be innovative because if you keep doing the same thing over and over, eventually it becomes stale and is destined to fail. Success in E&C requires the ability to be creative and see the novel solutions and change necessary to keep your program successful. Learn more about your ad choices. Visit megaphone.fm/adchoices
How does Fahrenheit 451 foretell non-compliance regulation in Germany? Tom and Jay brave the surge in Covid cases by staying safe at home to tell the tale. They are back to look at top compliance articles and stories which caught their eye this week. OFAC focusing on screening errors. Mike Volkov with a 3-part series on Corruption Crime and Compliance. Part 1, Part 2 and Part 3 There is no single panacea for stopping corruption. Matthew Stephenson in GAB. 5 top steps for data transfer after Schrems III. Neil Hodge in Compliance Week. (sub req’d) What’s the cost of non-compliance? For Wells Fargo, a staggering $15.8 Billion. Matt Kelly explores on Radical Compliance. Fahrenheit 451, compliance and German regulators? Rosemary Lark considers in the FCPA Blog. Coronavirus Comeback planner. Navex Global’s Ethics and Compliance Matters. A compliance approach to excessive force in policing. Joseph Murphy and Emil Moschella in NYU’s Compliance and Enforcement Crisis preparedness and the BOD? Joydip Day explores in CCI. This month on The Compliance Life, I am joined by Louis Sapirman. In Part 1, we looked at Louis personal and professional journey into compliance. AMI week on Compliance and Coronavirus as Maurice Gilbert discusses the compliance hiring scene Covid-19, Andy Goldstrom on business sustainability; and Laura Petrolino on storytelling for communications. On the Compliance Podcast Network, Tom begins a new month on 31 Days to a More Effective Compliance Program, this month focusing on the role of the Board in compliance. This week saw the following offerings: Monday-legal obligations of the BOD; Tuesday- prudent discharge of BOD obligations; Wednesday-BOD Compliance Committees; Thursday- OIG guidance for BODs; and Friday-Compliance expertise on the BOD. The month of July is being sponsored by Affiliated Monitors. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What are some of the skills a CCO needs to success navigate the compliance waters in any company? What are some of the top challenges CCOs have faced and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, my guest is Louis Sapirman, Vice President, Chief Ethics & Compliance Officer and Chief Compliance Counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corporation. He oversees the company's regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic's longstanding values in their work. Louis previously served as Associate General Counsel & Chief Compliance Officer for the Dun & Bradstreet Corporation. During his tenure as CCO, the company was recognized as one of the World's Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms including Wilmer Cutler Pickering Hale & Dorr and Buchanan Ingersoll. Throughout his career, Louis has been recognized for his work. In both 2015 and 2016, the Ethisphere Institute named him to their list of Attorneys Who Matter in Compliance and Ethics, and in 2010 he was named International Employment Lawyer of the Year by the Association of Corporate Counsel. In this first episode, we consider Louis' personal and professional journey into the field of compliance. We get to know Sapirman through his family and why he is so passionate about compliance, institutional justice and institutional fairness. We learn about two experiences growing up that helped informed his views on diversity and the wider world. He talks about his experience as a member of a service fraternity in college and then moves into his professional career. His legal work as a Generalist into Employment Attorney, moving to Employment and Litigation work at D&B and then revamping the investigations process at D&B. Learn more about your ad choices. Visit megaphone.fm/adchoices
This episode features Louis Sapirman, chief ethics and compliance officer at Panasonic North America, who talks with LRN’s Ben DiPietro about the need for empathy by companies during the pandemic, the ways companies can help address racial injustice, and what it means to be the white parent of an adopted Black teen-aged son in 2020 America. “Corporate America is a great Petri dish for building the type of society that we actually want externally. I would challenge all companies to take the time, not just to talk, not just to communicate...but to take the time to look within themselves and say what can we do to strengthen our own cultures...so that it reflects the way we want society as a whole to be.” - Louis Sapirman Louis A. Sapirman is the chief ethics and compliance officer and chief compliance counsel for Panasonic Corporation of North America, the principal North American subsidiary of Panasonic Corp. He oversees the company’s regulatory and compliance function, maintaining a culture of ethics, and ensuring all employees are upholding Panasonic's values in their work. Sapirman previously served as associate general counsel and chief compliance officer for the Dun & Bradstreet Corp. During his tenure, the company was recognized as one of the World’s Most Ethical Companies by the Ethisphere Institute. Prior to moving in-house, Louis worked in private practice with several law firms, including Wilmer Cutler Pickering Hale & Dorr, and Buchanan Ingersoll. He earned his bachelor’s degree in philosophy from the State University of New York-College at Geneseo, and his Juris Doctorate from Rutgers School of Law in Newark, N.J. Outside of work, Sapirman is an avid volunteer, including his work with the Giving Network, and as a former member of the Board of Trustees of Rutgers University. What You’ll Learn on This Episode: [1:06] What sparked Sapirman’s interest in ethics and compliance and how has his career path led him to his current role? [3:43] What are some of Panasonic’s core values? [4:41] What were Sapirman’s goals after joining the company and how has Covid affected their progress? [6:50] What are some of Sapirman’s concerns from a ethics and compliance perspective as it relates to reopening post-Covid? [8:23] How can employers handle employees who are reluctant to return to in-office work? [13:38] How has Sapirman’s experience with his own son shaped how he views the current climate? Find this episode of Principled on Apple Podcasts, Google Podcasts, Stitcher, Sound Cloud, Podyssey, or anywhere you listen to podcasts.
As the St. Patrick’s Day weekend is past and Spring has sprung all over Tom and Jay are back to take a look at some of this week’s top compliance and ethics stories which caught their collective eyes this week. 1. What are some of the lessons for compliance professionals from the college admissions scandal? 2. How did the FCPA Corporate Enforcement Policy change for messaging apps? 3. What’s the difference between concurrent, consecutive and stacked? 4. Even the big dogs can be defrauded. Kristen Broughton reports on fraud which cost Google and Facebook over $100MM.5. Training wheels will continue to be useful in the future. 6. The business response leads to better compliance through FinTech. 7. Cyber breach disclosures are a mess. Matt Kelly reports. 8. The Editor speaks on insider threats. Compliance Week Editor Dave Lefort discusses.9. Jaclyn Jaeger looks inside the FBI Office of Integrity.10. Following up on his blog post series on the MTS FCPA settlement, Tom moves to the audio format for a podcast series on the enforcement action.Check out the following: Part 1-background;Part 2-bribery schemes; Part 3- missed red flags; Part 4-the individual indictments; and Part 5-lessons learned. 11. In Houston on Tuesday? Join Tom and Katie Smith at Convercen’s Roundtable Lunch. Registration and information are here. If you are not in Houston, then join Tom, Louis Sapirman and Katelyn Conlyn for a Convercent webinar on how to better engage with your employees. Registration and information for the webinar found here. Best of all, both events are FREE.12. Check out the latest edition of Popcorn and Compliancewhere Tom and Jay looked at Captain Marvel from the compliance perspective. 13. Join Tom and AMI’s Jesse Caplan next week for a 5-part exploration of emerging issues in healthcare compliance and monitoring. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
In February 2019, Tom Fox and Louis Sapirman joined Hanzo for a webinar all about the risks and opportunities that exist between compliance and marketing teams. These highlights from the hour-long webinar dive into their thoughts, guidance, advice, experiences, and strategies around improving the effectiveness of a compliance program through marketing best practices, and how compliance teams can overcome common social media and marketing risks to protect their brand and organization.
A special guest joins the lads this week. Tom and Jay were panelists this week’s at Assent’s Supply Chain Conference as was our guest Pamela Fierst-Walsh who joins in for this special live edition of This Week in FCPA. The trio share their observations around one of the areas of renewed compliance focus and are back to at some of this week’s top compliance and ethics stories which caught their collective eyes. 1. KPMG executives go to trial in alleged theft of PCAOB audit protocols. 2. Hawiian businessman pleads guilty to FCPA violations. 3. Do you know who is in your supply chain? Matt Kelly on the Anheuser-Busch commercial featuring Bon & Viv. Matt and Tom consider more deeply in this week’s episode of Compliance into the Weeds.4. Why is the ‘ethics’ portion of a compliance and ethics program more important than ever? 5. Avoiding female colleagues is not the answer to #MeToo. It’s discrimination. 6. Why is health care in China still a minefield for compliance? 7. What are some great digital markets strategies for compliance? 8. How does organizational culture impact compliance? 9. Have you been microchipped? 10. Tom has a 5-part podcast series celebrating the 15th anniversary of the founding of Affiliated Monitors. 11. Tom and Louis Sapirman are joined by Sean Freidlin for a Hanzo sponsored webinar on February 28 on the intersection of a corporate compliance program and corporate communications and marketing. Learn about knocking down silos and using social media in your compliance program. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
A special guest joins the lads this week. Tom and Jay were panelists this week’s at Assent’s Supply Chain Conference as was our guest Pamela Fierst-Walsh who joins in for this special live edition of This Week in FCPA. The trio share their observations around one of the areas of renewed compliance focus and are back to at some of this week’s top compliance and ethics stories which caught their collective eyes. 1. KPMG executives go to trial in alleged theft of PCAOB audit protocols. 2. Hawiian businessman pleads guilty to FCPA violations. 3. Do you know who is in your supply chain? Matt Kelly on the Anheuser-Busch commercial featuring Bon & Viv. Matt and Tom consider more deeply in this week’s episode of Compliance into the Weeds.4. Why is the ‘ethics’ portion of a compliance and ethics program more important than ever? 5. Avoiding female colleagues is not the answer to #MeToo. It’s discrimination. 6. Why is health care in China still a minefield for compliance? 7. What are some great digital markets strategies for compliance? 8. How does organizational culture impact compliance? 9. Have you been microchipped? 10. Tom has a 5-part podcast series celebrating the 15th anniversary of the founding of Affiliated Monitors. 11. Tom and Louis Sapirman are joined by Sean Freidlin for a Hanzo sponsored webinar on February 28 on the intersection of a corporate compliance program and corporate communications and marketing. Learn about knocking down silos and using social media in your compliance program. Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com. For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com. Learn more about your ad choices. Visit megaphone.fm/adchoices
In our inaugural episode, former CCO Louis Sapirman chats with Tom Fox about his 360-Degrees of Compliance Communication model, which takes an all-encompassing approach to compliance messaging.
I am a huge fan of using social media in your compliance function. I often point to Louis Sapirman, the Vice President, Associate General Counsel and Chief Compliance Officer at Dun & Bradstreet, as an example of a company and CCO that has embraced the use of social media to advance their best practices compliance program. But how can you get your arms around how to structure such a program for their company? Learn more about your ad choices. Visit megaphone.fm/adchoices
How does one company and one Chief Compliance Officer (CCO) actively use social media to make more effective the company’s compliance culture. The company is the Dun & Bradstreet (D&B) and its CCO, Louis Sapirman, whom I visited with about his company’s integration of social media into compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode, Jay and I are joined by Louis Sapirman, CCO at Dun & Bradstreet for a look the the 2017 SCCE Compliance and Ethics Institute. We discuss the pro-conference events, what we hope to achieve at this year's event and why it is important to give back to the compliance community. We end with a discussion on why the Harvey Weinstein affair may well change the face of compliance going forward. Learn more about your ad choices. Visit megaphone.fm/adchoices
In this episode, Jay and I are joined by Louis Sapirman, CCO at Dun & Bradstreet for a look the the 2017 SCCE Compliance and Ethics Institute. We discuss the pro-conference events, what we hope to achieve at this year's event and why it is important to give back to the compliance community. We end with a discussion on why the Harvey Weinstein affair may well change the face of compliance going forward. Learn more about your ad choices. Visit megaphone.fm/adchoices
Yesterday I considered an article by Ryan Hubbs, entitled “10 Factors Leading to Reporting Mechanism Distrust”, in which he detailed 10 factors leading to hotline distrust. Today I want to pick up on that article with Hobbs' tips for building a trusted hotline reporting program and culture, talk about the SEC whistle blowing program, and conclude with a few thoughts on why experienced, invested counsel is so critical in these. Organizations implement and maintain hotlines, trusted programs, hotline programs differently depending on their sizes, cultures, geography, and many other factors if they must decide if they'll construct such programs. Many organizations find benefit to taking it outside from the experience and expertise, the appearance of independence which can increase employee trust. A smaller organization may not be able to do so. Nevertheless, there are many competent companies that put on hotline services for small individuals. What can you do to help build trust for your reporting system? 1. Training and awareness. Increased awareness of the program will help build employee's confidence around it, and organization should continually strive to help employees know that the hotline reporting system program works, why the organization believes in it, who operates it, and why it's a critical part of the culture of the company and the compliance ethos of the company. Organizations should include hotline frequently asked questions and answers for all employee new hires and supervisory training. Ongoing communication. Communication about a hotline reporting program, recent compliance issues, and messages from management should be a routine and commonplace. I have talked about putting posters in workrooms and coffee rooms to announce hotlines, but you have to continually communicate it. Think of the example of Louis Sapirman at Dun & Bradstreet, where they are continually communicating via the company's internal social media program about the hotline. Accessibility. Information on a hotline reporting program and how to report a concern should be within one click of the organization's intranet or external website. An organization should communicate program information in as many languages is as necessary to provide coverage. Certainly here, the Department of Justice and Securities Exchange Commission have made clear in the 2012 guidance that local languages must be respected and utilized. Web-based reporting platforms should be available to facilitate anonymous reporting and allow for inclusion of attachments. Conversely, you may have a situation where a large amount of your workforce does not have access to a computer. They may be in a country where there's limited internet or, frankly, they may not be trained on computers, so you be required to maintain other mechanisms as well. Transparency. Prominently display your organization's hotline reporting and investigative process including the expertise and contact information of your trained investigators, what employees should expect, plus the organization's responsibilities, cooperate, and protecting against retaliation. We have talked about anti-retaliation before, but I'm going to emphasize it again because it is so important. You must incorporate the fair process doctrine, you must not retaliate, and you must make clear to your employees that you will not tolerate retaliation. Proficiency and objectivity. Those who manage the hotline and investigation process should be technically proficient, professional, well trained, and experienced in the handling and reporting of concerns. The organization should also install adequate systems, processes, and technologies to support the investigators and ultimately the employees. This includes an in depth and routine training, I would say no less than annually, for the organization's investigative, legal, HR, and compliance staff, but you've got to get the word out. You got to have proficiency and objectivity. Prong three of the 2016 Department of Justice pilot program required compliance expertise. You must have that proficiency and it should include into your investigative staff. Ongoing assessment. Is your organization assessing your compliance program and your hotline? How do employees currently view the hotline reporting program and corporate culture? Can people get the information to the appropriate disciplines within your organization? Here you can think about Wells Fargo, where there was clear evidence that the culture had failed yet even with a reporting mechanism in place and use of that mechanism, management did not follow up to determine the issues which led to the company’s catastrophic reputational damage. Next, is an assessment on whether the ethics and hotline policies, procedures, and technology are meeting the needs of the organization and the employees. Here let me emphasize technologies, because I earlier about a situation where an employee does not have access to a computer. What if the employees are out on a drilling rig? Would they have access to a cell phone, or could they report in that manner? Maybe not. They may have to use a computer. You must have the appropriate technology for your diverse workforce. What about after the report is made? Are your internal investigations and resulting disciplinary actions consistent with the organization's desired culture of compliance? Here you need to make sure that the actions you have taken really are consistent because employees understand this and they will watch and see what happens. Are independent reviews conducted by internal audit or external professionals with ongoing oversight by an audit committee of the hotline and results? Finally, are complaints and resolutions disclosed to or discussed with external auditors? Are you bringing in outside experts to help you? All of this is important because of Dodd-Frank and its creation of a Whistleblower program for securities violations, such as the Foreign Corrupt Practices Act (FCPA) for issuers. As of April, of 2017, the Securities and Exchange Commission (SEC) has made 43 whistle blowers awards of over $153 million to whistle blowers under the Whistleblower program established under Dodd-Frank. This is a direct result of failure of corporate hotlines. Any regulator will tell you that 95% of all employees attempted to report internally first and they were either rebuffed, they were retaliated against, or in some other way rejected. The amount of money, fines and penalties, paid out for ignoring whistle blowers, people who report anonymously, is significant. Finally, as I end this one-month series, I would just like to re-emphasize the need for experienced investigative counsel for serious matters. Recently had a declination issued in the Linde Gas case by the Department of Justice (DOJ), and it really was clear that the counsel used by Linde in in addition to the decision self-disclose, was a critical factor in Linde getting the superior decision it did, which was a declination to prosecute. The investigation was a very difficult set of facts, very convoluted, very muddled up over many countries with shell companies, direct companies, and others. You really must have experienced investigative counsel for things that are outside the routine. Having an experienced, season and competent FCPA bar-lawyer who could both investigate it and negotiate with the government is very critical going forward. Three Key Takeaways Work to engender employee trust. The SEC Whistleblower program is a huge success and is not going away. Use experienced investigative counsel for hotlines reports of serious wrongdoing. Learn more about your ad choices. Visit megaphone.fm/adchoices