Podcast appearances and mentions of roy snell

Post By: Adam Turteltaub The Environmental, Social and Governance (ESG) movement has been around for a long time, but over the last year it has hit a tipping point. In fact, according to Roy Snell, former SCCE & HCCA CEO and now advisor to Osprey ESG Software, it has hit several tipping points. In this podcast he and Alison Taylor, Executive Director of Ethical Systems, outline how strong the ESG movement has become and how important it is for compliance professionals to embrace it. They will also be addressing this topic at the SCCE ESG and Compliance Conference on June 17, 2021. As they share here, recently the EU announced it was looking to create regulations monitoring the truthfulness of ESG claims, particularly for investment firms. The US Securities & Exchange Commission (SEC) has set up an enforcement working group of its own. Standards bodies are emerging and setting some very high bars, and many organizations have committed to various ESG goals. One of the difficulties of ESG is that there is a mix, Alison notes, of hard and soft obligations. In the area of modern slavery, for example, many countries already have requirements in place for, at a minimum, reporting what the company is doing to managing the risk. And in environmental arena there are already a host of laws and regulations. But, in many other areas that fall under ESG there are not yet laws. Nevertheless, a corporate commitment should be taken just as seriously and with great rigor. In sum, ESG has come of age, and with it has come the risk that organizations will start fudging the numbers to meet their proclaimed and required ESG goals. That leads to an opportunity and need for compliance teams to get involved. As in other areas, compliance should not necessarily be directly involved in the initiatives since it can create a conflict of interest. Instead, they advise, compliance should, as it traditionally has, ensure the integrity of the organization’s work by creating control processes and procedures and investigating claims of potential wrongdoing. For the compliance team to be effective they recommend working with related units in the organization: ESG, corporate social responsibility, sustainability and investor relations. Increasingly investors are demanding that organizations report on their ESG efforts, and that has caught the attention of leadership and the board. Listen in to learn more, and then join us at the SCCE ESG and Compliance Conference.

Post By: Adam Turteltaub Group think, confirmation bias and a lack of critical thinking can all cause lapses in integrity. Seeing high levels of all three led Roy Snell, the former CEO of the Society of Corporate Compliance and Ethics & Health Care Compliance Association, to write IntegrityWorks: Tools and Skills to Build Integrity. The book was just published and is now available for sale on the sites of the HCCA and SCCE. In this podcast, Roy and his editor Karen Latchana Kenney discuss the risks to integrity and what can be done about them. They also discuss the four chapters of the book, which address bias, being genuine, truth and civil debate, and critical thinking. Designed to be a useful tool, rather than a philosophical discussion, IntegrityWorks provides workshop ideas for putting integrity into practice. It also includes interviews with ethical leaders, and presents integrity in a number of different and compelling ways. Listen in to learn more, and then order your copy of IntegrityWorks from the HCCA or SCCE websites.

By Adam Turteltaub adam.turteltaub@corporatecompliance.org Roy Snell must have written a book’s worth of material each year as the CEO of The Society of Corporate Compliance and Ethics and Health Care Compliance Association, but it wasn’t until recently that he wrote an actual book.  The Accidental Compliance Professional is the first, of potentially several, from Roy. He sat down for a podcast, along with the book’s editor, Karen Latchana Kenney to discuss how the book was developed and written.  It started out, they explained, with the idea of giving some history of compliance but quickly evolved into a vehicle to tell stories and share what Roy had learned along the way. Listen in as they discuss: How even accidental compliance professionals may have ended up in the job for very good reasons The genesis and purpose of Roy-isms and Roy’s rules The value in learning from mistakes The importance of compliance officer independence How conflicts of interest can get in the way of preventing, finding and fixing problems

In this episode, we report from the SCCE 2017 Compliance and Ethics Institute, which was recently concluded in Las Vegas. We are joined by Roy Snell, the President of SCCE. We all relate some of our highlights of this year's events and look at some of the most recent compliance and ethics stories which caught our collective eyes.  Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, we report from the SCCE 2017 Compliance and Ethics Institute, which was recently concluded in Las Vegas. We are joined by Roy Snell, the President of SCCE. We all relate some of our highlights of this year's events and look at some of the most recent compliance and ethics stories which caught our collective eyes.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Today is the second half of my conversation with Roy Snell, CEO of the Healthcare Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE). In this episode we talk about communicating with the Board and leadership, operational integration, the future of the compliance profession and the future of the HCCA/SCCE. Remember to subscribe to the show!  Disclaimer: On this podcast I speak only for myself and what I share are simply my opinions. My guests also speak only for themselves and do not represent the opinions of their firms or organizations. All content provided on this podcast is for information purposes and neither I or my guests make any representations as to the accuracy or completeness of any information on the show or in the show notes. This podcast should not be used in any legal capacity whatsoever. Please consult a qualified attorney before taking any action that could have legal implications to you or your business.

In this episode, Roy Snell and I have a wide ranging discussion on the SCCE's Compliance and Ethics Institute. Learn more about your ad choices. Visit megaphone.fm/adchoices

Today on the show we are talking with Roy Snell, CEO of the Healthcare Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE). Roy and I go in depth into the HCCA/OIG Resource Guide on Compliance Program Effectiveness, including the back story behind the collaboration and how to use the guide in your own program. We also talk about the Department of Justice Fraud Division Memo on Evaluating Compliance Programs and Roy discusses why he thinks the memo is probably the second most important document in our profession. I've divided up our conversation into two episodes so be sure to come back next week for the second half of the conversation where we talk about the future of the compliance profession and much more.  Remember to subscribe to the show!  Disclaimer: On this podcast I speak only for myself and what I share are simply my opinions. My guests also speak only for themselves and do not represent the opinions of their firms or organizations. All content provided on this podcast is for information purposes and neither I or my guests make any representations as to the accuracy or completeness of any information on the show or in the show notes. This podcast should not be used in any legal capacity whatsoever. Please consult a qualified attorney before taking any action that could have legal implications to you or your business.

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: HSBC monitor report protected from release. See article in Reuters by clicking  here.The Odebrecht scandal continues to resonate across South America. See Dick Cassin’s post in the  FCPA Blog.The first half of 2017 has brought the final resolutions of only two FCPA matters from the new administration, but they were both declinations. Both declinations have significantly strengthened the FCPA Pilot Program as a clear path forward for every company that finds itself in FCPA hot water. See Tom’s article in  Compliance Week.Roy Snell says it’s not who’s who but who gets it. See article in SCCE Compliance and Ethics Blog.Tom announces the rollout of the Compliance Podcast Network. It includes This Week in FCPA, FCPA Compliance Report, Compliance Report-International Edition, 12 O’Clock High, Unfair and Unbalanced, Compliance into the Weeds, Across the Board, Everything Compliance, One Month to a More Effective Compliance Program. See Tom’s article in the FCPA Compliance and Ethics Blog.The next Everything Compliance podcast is in production. Topics include Walter Shaub’s departure from OGE and does it even matter? Jesse Eisinger’s book The Chickenshit Club; the SFO, UK Bribery Act and the Rolls-Royce enforcement action; differences in DPA practice in the US & UK; Trump Administration & FCPA enforcement; EU’s GDPR; and Hui Chen’s departure from Justice Department; both her public rebuke of Trump, and the substance of how she believes her guidance has been mis-interpreted. Part I will go up on Thursday, July 20. Learn more about your ad choices. Visit megaphone.fm/adchoices

This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: HSBC monitor report protected from release. See article in Reuters by clicking here. The Odebrecht scandal continues to resonate across South America. See Dick Cassin’s post in the FCPA Blog. The first half of 2017 has brought the final resolutions of only two FCPA matters from the new administration, but they were both declinations. Both declinations have significantly strengthened the FCPA Pilot Program as a clear path forward for every company that finds itself in FCPA hot water. See Tom’s article in Compliance Week. Roy Snell says it’s not who’s who but who gets it. See article in SCCE Compliance and Ethics Blog. Tom announces the rollout of the Compliance Podcast Network. It includes This Week in FCPA, FCPA Compliance Report, Compliance Report-International Edition, 12 O’Clock High, Unfair and Unbalanced, Compliance into the Weeds, Across the Board, Everything Compliance, One Month to a More Effective Compliance Program. See Tom’s article in the FCPA Compliance and Ethics Blog. The next Everything Compliance podcast is in production. Topics include Walter Shaub’s departure from OGE and does it even matter? Jesse Eisinger’s book The Chickenshit Club; the SFO, UK Bribery Act and the Rolls-Royce enforcement action; differences in DPA practice in the US & UK; Trump Administration & FCPA enforcement; EU’s GDPR; and Hui Chen’s departure from Justice Department; both her public rebuke of Trump, and the substance of how she believes her guidance has been mis-interpreted. Part I will go up on Thursday, July 20. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, I visit with Roy Snell about his recent announcement that he is stepping down as head of the SCCE. We review the current state of the SCCE and how the Roy has seen the compliance evolve from its start after the 1992 US Sentencing Guidelines. We discuss where Roy sees compliance going in the next several years and where the SCCE may go to support the profession.  This announcement comes when the SCCE has grown to 50 staff members and one of the has one of the strongest boards in the professional association world. the SCCE has a strong footprint in the US and is a material player internationally with 17,500 members in 95 countries. It has a great reputation and its success to date has been quite remarkable.  The call for applications will close on August 20th 2017.  A detailed job description and position summary are available at http://www.corporatecompliance.org/CEO.  SCCE plans to complete the interview and selection process in the Fall of 2017 and onboard a Deputy CEO in early 2018. The Deputy CEO will likely assume the role of the CEO sometime in 2019. Roy will stay on with the organization for roughly one year to work on special projects. To be considered for the CEO of SCCE and HCCA, please fill out the questionnaire with return instructions available at: http://www.corporatecompliance.org/CEO. Learn more about your ad choices. Visit megaphone.fm/adchoices

Episode 18 Show Notes  I. Compensation, Incentive and Compliance In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the organization and for keeping workers focused on activities that help the bottom line. At the same time, however, the incentives can pose great risks.  Many corporate scandals have shown that workers and corporate leaders may give in to the temptation to cheat to make their numbers, doing whatever they can to achieve their goals and reap the rewards. As a consequence, incentive plans may turn out to be a roadmap for compliance risk.  This danger argues for the compliance department having a role in reviewing incentive plans, if nothing else than to develop controls that ensure the numbers are hit properly, without violating policies, procedures, the law, and ethical norms.  To better assess the role of the compliance team in reviewing incentive plans, in April 2017 the Society of Corporate Compliance and Ethics and the Health Care Compliance Association fielded a survey among compliance professionals. The results indicate that, despite the risks, compliance rarely plays a role in evaluating incentive programs. For the recent SCCE/HCCA survey on this issue, click here. For additional writings by Tom see the following blog posts:  Incentivizing Compliance Executives and Compliance Compensation Incentives Sales Incentives and Compliance II. Compliance and the Board of Directors On a second topic, Roy and I discuss the need that a true compliance expert sit on a company’s Board of Directors. The presence of a such a compliance professional with subject matter expertise on the Board sends a strong message about the organization’s commitment to compliance, provides a valuable resource to other Board members, and helps the Board better fulfill its oversight obligations. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar background and often times these are also the Audit Committee members of the Board. Such a background brings a level of sophistication, training and subject matter expertise that can help all companies with their financial reporting and other finance based issues. So why is there not such compliance subject matter expertise at the Board level?  Roy sees it through the prism of the compliance profession and has said, “If you ask most companies if they have compliance expertise on their Board… most would say yes. When asked who the compliance expert is they typically point to a lawyer, auditor, risk manager, or an ethicist. None of these professions are automatically compliance experts. All lawyers have different specialties.” He goes on to state that what regulators want to see is specific compliance expertise at the Board level. He noted, “the government is looking for is not generic compliance expertise. They are looking for compliance program management expertise.  For Roy’s further thoughts on this issues, see his blog post, “Compliance Expertise Needed on Your Board”.  For Tom’s writing on the subject see his blog post, “Compliance Expertise Needed on the Board”.       Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, Roy Snell and I discuss the following: Measuring the effectiveness of your compliance program three ways; Why Roy thinks the CO shouldn’t chair the compliance committee – but maybe the general counsel should; Who I think should chair the compliance committee; Why you should prove your point 5 different ways instead of just 1; Brexit: Keep Calm and Do Compliance; and How Compliance transcends politics. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this Part I of a two part series recorded at this month's European Compliance and Ethics Institute in Prague, Roy Snell discuss the DOJ's Evaluation of Corporate Compliance Programs in the context of cavemen and Plato's Analogy of the Cave. We review some of the new information and Roy discusses how it is a compilation of many differing strands of compliance thought over the past 20 year. We then discuss the HCCA-OIG Resource Guide on Measuring Compliance Program Effectiveness. As always we go off on tangents and dive deeply into issues relating to the the compliance profession.  Learn more about your ad choices. Visit megaphone.fm/adchoices

  In this episode, Jay and I have a wide-ranging discussion on why good compliance and is good for business. We discuss:  LRN Ethics and Compliance Program Effectiveness Report. Click here for Report.Ethisphere’s 2017 World’s Most Ethical Companies. Click here for Report.Why good compliance is good for business. See Tom’s blog post.Women in compliance: A key to organizational diversity. See article in the  FCPA Blog.ECI Podcast: Engaging With Your Monitor: Best Practices from ECI’s Independent Monitor Benchmarking Group. To listen to the podcast, click here.Jay previews his weekend report.Tom previews a presentation he will give with Jenny O’Brien and Roy Snell at the SCCE European Ethics and Compliance Institute in April. Jay previews a presentation at the same event by Eric Feldman of Affiliated Monitors. For more information on the event, check it out by clicking here. Jay Rosen new contact information: Jay Rosen, CCEP Vice President, Business Development Monitoring Specialist  Affiliated Monitors, Inc. Mobile (310) 729-6746 Toll Free (866)-201-0903 JRosen@affiliatedmonitors.com Learn more about your ad choices. Visit megaphone.fm/adchoices

  In this episode, Jay and I have a wide-ranging discussion on why good compliance and is good for business. We discuss:  LRN Ethics and Compliance Program Effectiveness Report. Click here for Report. Ethisphere’s 2017 World’s Most Ethical Companies. Click here for Report. Why good compliance is good for business. See Tom’s blog post. Women in compliance: A key to organizational diversity. See article in the FCPA Blog. ECI Podcast: Engaging With Your Monitor: Best Practices from ECI’s Independent Monitor Benchmarking Group. To listen to the podcast, click here. Jay previews his weekend report. Tom previews a presentation he will give with Jenny O’Brien and Roy Snell at the SCCE European Ethics and Compliance Institute in April. Jay previews a presentation at the same event by Eric Feldman of Affiliated Monitors. For more information on the event, check it out by clicking here.  Jay Rosen new contact information: Jay Rosen, CCEP Vice President, Business Development Monitoring Specialist  Affiliated Monitors, Inc. Mobile (310) 729-6746 Toll Free (866)-201-0903 JRosen@affiliatedmonitors.com Learn more about your ad choices. Visit megaphone.fm/adchoices

Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar background and often times these are also the Audit Committee members of the Board. Such a background brings a level of sophistication, training and subject matter expertise that can help all companies with their financial reporting and other finance based issues. So why is there not such compliance subject matter expertise at the Board level?  An arm of the US government has recognized the need for such expertise at the Board level. In 2015 the Office of Inspector General (OIG) has called for greater compliance expertise at the Board level. The OIG said that a Board can raise its level of substantive expertise with respect to regulatory and compliance matters by adding to the Board, a compliance member. The presence of a such a compliance professional with subject matter expertise on the Board sends a strong message about the organization’s commitment to compliance, provides a valuable resource to other Board members, and helps the Board better fulfill its oversight obligations. Mike Volkov looked at it from both a practical and business perspective and has stated, “I have witnessed firsthand that companies that have a board member with compliance expertise usually have a more aggressive and effective compliance program. In this situation, a Chief Compliance Officer has to answer to the board for the company’s compliance program, while receiving the resources and support to accomplish compliance tasks.”  Roy Snell sees it through the prism of the compliance profession and has said, “If you ask most companies if they have compliance expertise on their Board… most would say yes. When asked who the compliance expert is they typically point to a lawyer, auditor, risk manager, or an ethicists. None of these professions are automatically compliance experts. All lawyers have different specialties.” He goes on to state that what regulators want to see is specific compliance expertise at the Board level. He noted, “the government is looking for is not generic compliance expertise. They are looking for compliance program management expertise. Hui Chen, the DOJ Compliance Counsel, has continually talked about the need for companies to operationalize their compliance programs. She intones businesses must work to literally burn compliance into the fabric and DNA of their organization. Having a Board member with specific compliance expertise, heading a Board level Compliance Committee can provide a level of oversight and commitment to achieving this goal. It will not be long before the DOJ and SEC begin to require this step in any FCPA enforcement action resolution. This means that when your company is evaluated by Chen, under the factors set out in Prong Three of the FCPA Pilot Program, to retrospectively determine if your company had a best practices compliance program in place at the time of any violation, you need to have not only the structure of the Board level Compliance Committee but also the specific subject matter expertise on the Board and on that committee.  Key Takeaways Boards must have compliance expertise. Government regulators and shareholder groups have both called for greater compliance expertise at the Board. Compliance expertise at the Board works up and down as such expertise can be a resource to both the CCO and compliance department. For more information, check out my book Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program, which is available by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices

Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar background and often times these are also the Audit Committee members of the Board. Such a background brings a level of sophistication, training and subject matter expertise that can help all companies with their financial reporting and other finance based issues. So why is there not such compliance subject matter expertise at the Board level? An arm of the US government has recognized the need for such expertise at the Board level. In 2015 the Office of Inspector General (OIG) has called for greater compliance expertise at the Board level. The OIG said that a Board can raise its level of substantive expertise with respect to regulatory and compliance matters by adding to the Board, a compliance member. The presence of a such a compliance professional with subject matter expertise on the Board sends a strong message about the organization’s commitment to compliance, provides a valuable resource to other Board members, and helps the Board better fulfill its oversight obligations. Mike Volkov looked at it from both a practical and business perspective and has stated, “I have witnessed firsthand that companies that have a board member with compliance expertise usually have a more aggressive and effective compliance program. In this situation, a Chief Compliance Officer has to answer to the board for the company’s compliance program, while receiving the resources and support to accomplish compliance tasks.” Roy Snell sees it through the prism of the compliance profession and has said, “If you ask most companies if they have compliance expertise on their Board… most would say yes. When asked who the compliance expert is they typically point to a lawyer, auditor, risk manager, or an ethicists. None of these professions are automatically compliance experts. All lawyers have different specialties.” He goes on to state that what regulators want to see is specific compliance expertise at the Board level. He noted, “the government is looking for is not generic compliance expertise. They are looking for compliance program management expertise.   Hui Chen, the DOJ Compliance Counsel, has continually talked about the need for companies to operationalize their compliance programs. She intones businesses must work to literally burn compliance into the fabric and DNA of their organization. Having a Board member with specific compliance expertise, heading a Board level Compliance Committee can provide a level of oversight and commitment to achieving this goal. It will not be long before the DOJ and SEC begin to require this step in any FCPA enforcement action resolution. This means that when your company is evaluated by Chen, under the factors set out in Prong Three of the FCPA Pilot Program, to retrospectively determine if your company had a best practices compliance program in place at the time of any violation, you need to have not only the structure of the Board level Compliance Committee but also the specific subject matter expertise on the Board and on that committee.  Key Takeaways Boards must have compliance expertise. Government regulators and shareholder groups have both called for greater compliance expertise at the Board. Compliance expertise at the Board works up and down as such expertise can be a resource to both the CCO and compliance department. For more information, check out my book Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program, which is available by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices