Compliance Beat
by Eric Morehead
Join Eric Morehead as he cuts through the complicated topic of compliance and ethics. Compliance Beat is the podcast for professionals looking for answers. Stay up to date on current trends in compliance and ethics so that your program stays effective.
Episodes
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Three Keys to Evaluating or Benchmarking a Code of Conduct
Drawing again from his upcoming presentation at the SCCE Compliance and Ethics Institute on September 21, 2021, Eric discusses some key criteria to consider when evaluating or benchmarking a code of conduct.
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Three Code Launch Ideas
Eric discusses the upcoming 20th Annual SCCE Compliance and Ethics Institute and his presentation "Lessons from Sixty Code of Conduct Projects: What Are Five Things You Need for a Best-In-Class Code?" (scce-2021-cei-brochure.pdf (corporatecompliance.org) and, in particular, we focus on some key...
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Three Helpful Compliance Data Points from the US Sentencing Commission
In this episode Eric discusses the upcoming SCCE CEI event in Las Vegas (20th Annual Compliance & Ethics Institute | SCCE Official Site (corporatecompliance.org)), and in particular, one of the sessions he will be co-presenting with Kathleen Grilli from the US Sentencing Commission, "Thirty Years...
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Do We Need a Third-Party or Vendor Code of Conduct?
This time Eric spends a little time discussing why a company might want to have a third-party code of conduct, rather than relying only on their employee code of conduct. We discuss some of the reasons a third-party code is potentially a good idea, who the audience might be and what are some of…
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Top Three Mistakes Made When Tackling a Code of Conduct Project
This time Eric reviews the top mistakes he's seen clients and others make when tackling an code of conduct revision or rewrite process. Codes of Conduct are the foundation of any effective program and taking the appropriate care and time to complete a code revision project is the key to success.
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Three Considerations When Launching a New Code of Conduct
In this episode Eric discusses some considerations for a successful code of conduct launch. Often organizations spend a lot of time, effort and resources on revising and improving their code of conduct only to have little in the way of a launch effort. Eric discusses some ideas to avoid a failure...
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We're Back! Re-Introduction to Compliance Beat Podcast
After a extended hiatus, we're back! We're looking for your feedback on what to cover and what you'd like to hear about in the weeks going forward. Email us at: [email protected]
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3 Changes and 3 Things That Will Remain the Same for Compliance after Covid
It's been a year! We've seen challenges and changes -- and we're still not completely out of the woods yet. In this episode Eric talks about three of those seemingly permanent changes that compliance and ethics programs have had to deal with and also discusses three things that are definitely not...
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Compliance in the Age of Coronavirus: Tips for Remote Compliance
The world has changed since our last episode. Eric has some ideas for newly remote compliance officers handling newly remote workers. Communication is key, and the compliance team needs to make a special effort to be heard and involved.
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Three Reasons to Hire a Third Party for an Assessment
This time Eric discusses three primary reasons an organization might want to work with a third party to conduct a compliance program assessment.
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Keys to Benchmarking Your Code of Conduct
This time Eric walks through some categories to benchmark your code of conduct. Organizations are expected to regularly examine the effectiveness of their written standards and there are some common areas to review when taking stock of your code.
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Three Keys for Conflicts of Interest Compliance
This time Eric discusses three keys for a successful conflicts of interest compliance process. Eric discusses communication, disclosure, certification and tools that organizations can use to better address conflicts of interest risk.
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Three Essential Components for a Compliance Program Assessment
There are many ingredients for a successful compliance program assessment, but in this episode Eric focuses on three key components that are sometimes overlooked when an organization is either conducting their assessment internally or looking to a third-party to help them with a review.
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Three Myths About Anonymous Reporting Mechanisms
This time Eric talks anonymous reporting mechanism. What is actually required? What does reporting data show an compliance officer? What is the most effective reporting channel for an organization? We talk about these important questions and debunk a few myths about anonymous reporting.
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Three Questions to Ask Before You Start Your Compliance Communication Program
This time Eric spends some time talking about some practical considerations for organizations to consider when planning or revising their "informal" compliance communication program. This area of compliance has been changing quite rapidly and expectations are often high. To avoid disappointing...
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Perception and Retaliation, Part II
This is the second in a two-part discussion about perception and retaliation. This time we talk about solutions. How can an organization address the lingering perception of retaliation? We spend a few minutes looking at the data and discussing what you might do at your organization to address…
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Perception and Retaliation, Part I
This time Eric talks about retaliation. What does retaliation look like in an organization? How does perception of retaliation affect reporting? We spend a few minutes looking at the data and discussing what you should expect at your organization.
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Involving Managers in Compliance: The Three-Legged Stool of Tone at The Middle
Getting your managers involved in your compliance program is a best practice and also the most effective way to address compliance culture locally. In this episode Eric talks about three key criteria to consider when putting together a plan for involving managers: training, resources and...
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Sentencing Commission Confidential – Origins of the Hallmarks
As more and more compliance professionals join the ranks from other disciplines, it’s important that we reinforce the role of the US Sentencing Commission, and maybe even more importantly, the public’s role in defining the compliance and ethics standards all of our programs are based on. Listen…
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Sentencing Commission Confidential – Sentencing Data on Organizations
There’s not a lot of data out there to tell us how the Department of Justice or other regulators view compliance initiatives, or what expectations really are. We know what the guidance tells us, but what happens in the real world when a company’s compliance program is looked at? We can get some...
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Sentencing Commission Confidential – Personnel
For this episode Eric dives into the commonly conflated terms “substantial authority personnel” and “high-level personnel” that are defined in the Sentencing Guideline standards for an effective compliance and ethics program. Knowing which is which, and what the expectations are for a compliance...
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2019 SCCE Compliance and Ethics Institute Preview
Eric spends a few minutes looking back at CEI’s past — and talking about the threads and new trends in this year’s event. If you are visiting DC this week then come by and see Eric at Booth 106. If not, we hope to see you next time!...
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Privacy Bulletin: A Discussion on Privacy Compliance with Teresa Troester-Falk (PART II)
This time Eric is Teresa Troester-Falk to discuss the pending new privacy law from California, potential new laws in several states, and how it relates to GDPR and privacy compliance generally. This is the Second part of a two part conversation. If you haven’t listened to Part I we encourage you…
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Privacy Bulletin: A Discussion on the California Consumer Privacy Act and Privacy Compliance with Teresa Troester-Falk (PART I)
This time Eric is Teresa Troester-Falk to discuss the pending new privacy law from California and how it relates to GDPR and privacy compliance generally. This is the first part of a two part conversation. Join us next week for part two. Teresa is Chief Global Strategist for Nymity where she…
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Sentencing Commission Confidential: Who Speaks To The Board?
This time, in anticipation for a Sentencing Guideline presentation next month at the SCCE’s CEI in Washington DC, we have another belated edition of Sentencing Commission Confidential. Eric talks about a commonly overlooked or misunderstood part of Chapter Eight of the guidelines that sets out...
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Three Key Components for a Compliance Program Assessment
This time Eric discusses compliance program assessments – or risk assessments – or program benchmarking – or whatever you want to call the periodic review of your program that the Sentencing Guidelines, USDOJ guidance and best practices call for. Eric discusses three key pieces of the puzzle you...
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Do We Need Compliance Expertise on the Board?
One of the questions raised by the recent updated USDOJ guidance is the question of “expertise” at or on the board of directors. Eric takes some time this week to discuss the guidance and the practical considerations about expertise in the boardroom. If you are interested in the intersection of...
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3 Tips for an Excellent (Formal) Informal Communication Program
One of the areas many compliance teams still struggle with is getting a consistent, effective informal communication plan off the ground. Eric has a few ideas that might help focus informal communication efforts at your organization. Eric talks about being realistic regarding time and resources…
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New USDOJ Guidance -Conclusion
After a dozen episodes detailing the new guidance, what are some parting thoughts? Eric talks a little about the memo’s impact and potential impact as well as highlighting some of the more important concepts the Department has chosen to highlight.
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New USDOJ Guidance – Part 10 – Does It Work?
In Part 10 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric finishes discussing the memo! We will walk through Part III of the memo with a review of “Does the Corporation’s Program Work in Practice?” Check out the memo itself here:...
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New USDOJ Guidance – Part 9 – Incentives and Discipline
In Part 9 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric finishes discussing Part II of the memo with a review of incentives and discipline expectations. Check out the memo itself here:...
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New USDOJ Guidance – Part 8 – Resources
In Part 8 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the second topic in Part II of the memo: Autonomy and Resources. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download...
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New USDOJ Guidance – Part 7 – Management Commitment to Compliance
In Part 7 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the first topic in Part II of the memo: Commitment by Management — or tone from the top, middle and everywhere else! Check out the memo itself here:...
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New USDOJ Guidance – Part 6 – Third Parties
In Part 6 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the fifth and sixth topic in Part I of the memo: the “care and feeding” of third parties. Check out the memo itself here:...
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New USDOJ Guidance – Part 5 – Reporting
In Part 5 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the fourth topic in Part I of the memo: reporting. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download Also, please…
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New USDOJ Guidance – Part 4 – Training & Communication
In Part 4 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the third topic in Part I of the memo: training and communication. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download...
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New USDOJ Guidance – Part 3 – Policies and Procedures
In Part 3 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the second topic in Part I of the memo: policies and procedures. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download
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New USDOJ Guidance – Part 2 – Risk Assessment
In Part 2 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric discusses the first topic in Part I of the memo: risk assessment. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download
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New USDOJ Guidance – Part 1 – Introduction
Eric discusses the new memo from the US Department of Justice and its introduction and origins. Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download
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Breaking News! The US Department of Justice Releases New Compliance Program Guidance
Just yesterday the USDOJ announced a new memo regarding the evaluation of compliance programs. Eric has some initial thoughts, but stay tuned for more podcasts diving into the details. You can find the new memo here: https://www.justice.gov/criminal-fraud/page/file/937501/download
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Three Myths About Code of Conduct Development
Eric talks again about his favorite topic: code of conduct! This time we discuss three common code of conduct development myths. We talk about how longer does not equal better. How a global code that applies to everyone is better than a constellation of many codes. And finally Eric discusses how...
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Three Things You Might Not Know About the Organizational Sentencing Guidelines
This time Eric talks about three aspects of Chapter 8 of the Sentencing Guidelines that you may not have noticed before.
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Disclose, Disclose, Disclose: Some Thoughts on Conflict Disclosures
This time Eric talks through conflicts of interest disclosures. Who do you want to capture, what do you need to tell them, should you use tools? Eric talks through all of this and also spends some time talking about the types of questions you will want to ask in the disclosure questionnaire. Join...
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Small Businesses and Compliance
An important topic that we don’t talk enough about. Just as small businesses make up the vast majority of companies out there, and employ over 50% of the workforce in the USA, they also make up the majority of companies that get in the worst trouble for compliance failures — even though we rarely...
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Benchmarking Your Code or Written Compliance Standards
This time we discuss benchmarking. First we discuss how you might go about determining the peer codes of conduct (or other written compliance standards) that you can use for benchmarking purposes. You probably have a good idea of some peer organizations that might fit, but Eric also discusses…
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Three Questions to Ask Before You Launch a Compliance Survey
This time Eric talks about compliance surveys. Eric discusses what sort of content you might consider including in the survey instrument, whether you might want to consider benchmarking, and finally Eric discusses some of the practical elements of putting together a survey.
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Strategies for Reaching Remote Workers
This time Eric talks about three different areas to focus on when evaluating how you are reaching your remote workers to educate and inform them of the compliance program. Eric discusses use of local and existing resources, what resources should be developed by the compliance function and how...
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How Should the Board Be Involved in Compliance?
This time Eric discusses some considerations when looking at the role, responsibilities and relationships the board (or governing authority) of the organization with the operational personnel of the compliance and ethics program. There are a few key best practices to consider when evaluating the...
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What Are the Legal Requirements for A Code of Conduct?
In anticipation of our upcoming webinar on code of conduct development we talk today about what “requirements” for a code of conduct exist. Eric also provides a sneak peak into some of the content of the webinar by discussing the Department of Justice’s February 2017 memorandum and how that…
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How to Avoid All Compliance Risk…
How do you avoid all compliance risk? Hint: you can’t. This week Eric talks about some recent articles and discussions that suggest there might be a magic bullet or two (sometimes in the form of a new software tool) that will take away those pesky compliance concerns. We alk about the practical…
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About this show
Join Eric Morehead as he cuts through the complicated topic of compliance and ethics. Compliance Beat is the podcast for professionals looking for answers. Stay up to date on current trends in compliance and ethics so that your program stays effective.
Hosted by
Eric Morehead