The Massachusetts Office of Consumer Affairs and Business Regulation has provided guidance regarding its new regulations requiring all entities that own, license, store or maintain personal information about a resident of the Commonwealth of Massachusetts to develop, implement and maintain a comprehensive written information security program and make specific computer information security requirements. I mentioned…
Sarbanes-Oxley Act Whistleblower Digest
The U.S. Department of Labor assembled a digest of whistleblower law under the Sarbanes-Oxley Act. On July 30, 2002, the Sarbanes-Oxley Act of 2002, P.L. 107-204 was signed into law by President Bush. Section 806 of the Act, to be codified at 18 U.S.C. § 1514A, is a whistleblower provision that provides protection for employees…
Why Use a Hotline?
Is it important to have a hotline for reporting violations? Reporting violations is a keystone for an effective compliance program. It can maximize the eyes watching for lapses in judgment and blatant violations. It can foster the reporting of issues and concerns as they occur or before a violation occurs.
Ethics as a Business Process
Adam Turteltaub wrote Ethics as a Business Process for the fall 2005 edition of GRC 360. Forward-looking companies are seeking to evolve business from soft art to hard science as a means to win in the marketplace, improve competitive advantage, achieve higher market valuations, ensure employee retention, foster fruitful partnerships and strengthen customer satisfaction. ….
Real Money Laundering
The October 2008 edition (.pdf) of The SAR Activity Review, Trends, Tips and Issues published by the Financial Crimes Enforcement Network, has a great story on page 29 about a marijuana smuggling and money laundering operation. The organization was concerned that the cash smelled like marijuana. The benk tellers even noticed the smell of marijuana…
Whistleblower Policies
I ran across a few examples of whistleblower policies and whistleblower protection policies and some material on developing a whistleblower policy. Developing a Policy Developing a Whistleblower Policy (.pdf) by the Delaware Valley Grantmakers. Whistleblower Policies: Lessons For Associations by Julia E. Judish of Pillsbury Winthrop Shaw Pittman LLP National Whistleblowers Center Whistleblower Policy Safeguards…
Establishing an Effective Complaint-Handling Process
Grant Thornton put together a comprehensive report: Hear that whistle blowing! Establishing an effective complaint-handling process. (August 2006, .pdf) They have developed the MACH process which consists of six basic steps: Receive the complaint; Analyze the complaint; Investigate the complaint; Resolve the complaint; Report the resolution of the complaint; and Retain the necessary documentation.
Code of Ethics and Whistleblower Programs
A corporate code of ethics is the flip side of the coin of a whistleblower policy: The code of ethics is the principal means of communicating to all staff a strong culture of legal compliance and ethical integrity, while the whistleblower policy is a way to implement such values.
The Power of How presentation by Dov Seidman
LRN published the transcript of a presentation by Dov Seidman at the Center for Business Ethics at Bentley University: The Power of How: Achieving Enduring Success Through Ethics. Basically, in a world in which nothing stays hidden, you have to act as if you have nothing to hide. But before you can act as though…
Compliance at The Nature Conservancy
Back in 2004, The Nature Conservancy created the job of Chief Compliance Officer and formalized is compliance and governance policies. There is an interview with Karen Berky, Chief Compliance Officer in The Nature Conservancy’s 2004 Annual Report: Conservation That Works. Ms. Berky talks about the Conflict of Interest Policy and the Conflict of Interest Standard…