Compliance Perspectives show

Compliance Perspectives

Summary: Podcast featuring the top Compliance and Ethics thought leaders from around the globe. The Society of Corporate Compliance and Ethics and the Health Care Compliance Association will keep you up to date on enforcement trends, current events, and best practices in the compliance and ethics arena. To submit ideas and questions, please email:

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  • Artist: SCCE
  • Copyright: Society of Corporate Compliance & Ethics


 Mike Henry on Having a Successful Corporate Compliance & Ethics Week [Podcast] | File Type: audio/mpeg | Duration: 15:46

By Adam Turteltaub Each year the SCCE/HCCA encourages companies to participate in Corporate Compliance and Ethics Week.  For 2018 it will take place from November 4-10. Even if you don’t pick those dates, a week dedicated to compliance and ethics can have an enormous impact on your organization, and as Mike Henry, Senior US Counsel of Emera Energy points out, you don’t have to be a large organization to put a weeklong celebration together. Going into planning for the event, the goals were to contribute to a compliance culture at the company, increase understanding of compliance issues and create an environment of psychological safety where employees could ask important questions without fear. With four weeks to put together the program for the organization’s 200 employees, Mike and his colleagues focused on low-cost ways to generate interest such as building mystery and suspense. The week itself was timed to coincide with the annual compliance training, which helped put the training in context.  Seeing an opportunity to leverage a board meeting, an executive at the company invited a board member to speak on a culture of compliance panel that was a part of the weeklong activities. Listen in to learn more about how Emera made its compliance event a success, and, hopefully, pick up a few tips for your program.  Then, to learn more, come here Mike speak about it at the 2018 Compliance and Ethics Institute.

 Ted Banks on Ethical Considerations for Compliance and Ethics Officers [Podcast] | File Type: audio/mpeg | Duration: 15:58

By Adam Turteltaub While compliance and ethics professionals spend most of their time looking outward at the ethical considerations of others, there are definitely times to pause, and to look at their own ethical obligations. According to Ted Banks, a veteran compliance officer and partner at the firm Scharf Banks Marmor, that begins with recognizing that the compliance officer has to be an example and demonstrate ethical conduct all the time, and firmness about what is appropriate.  And, at the same time, there is a strong need not to be a jerk about it.  Much like SCCE/HCCA CEO Roy Snell recently wrote, a lack of political and communication skills, can lead to failure as a compliance officer. As importantly, the compliance officer needs to know that there are obligations to the company as well as to the public at large and to the compliance profession.  These are captured in the SCCE Code of Professional Ethics for Compliance Professionals. But how do you navigate these issues?  In this podcast Ted provides several pieces of practical advice: * Never consent to wrongdoing, but escalate the issue as high as necessary * Never abet or aid retaliation * Avoid personal conflicts of interest * Be honest in the results you and the compliance program can achieve * Understand technology, both its risks and opportunities * And, if you’re a lawyer, recognize you have legal code of professional responsibilities as well Listen in to learn more.  And to gain still more insights, be sure to attend his session at the 2018 Compliance and Ethics Institute.

 Brian Lee on Measuring Your Corporate Culture [Podcast] | File Type: audio/mpeg | Duration: 15:29

By Adam Turteltaub Getting a good sense of the corporate culture is often a challenging task.  Surveys, focus groups and just walking the hall can be instructive, but finding out what’s really going on may take a combination of all three. According to Brian Lee of Gartner (formerly CEB), you need first to have a sense of which makes the most sense for your organization.  Then, whatever option you choose, you need to ensure that you have created an environment where employees feel they can speak up honestly, you have a large enough sample to be valid, and the questions you ask deliver data that you can act on. From his experience, there are several factors that have an enormous effect on an employee’s view of the organization.  First is organization justice.  Second is comfort to speak up:  are they able to raise issues without fear of retaliation. Also of great importance is the climate around them:  not just tone at the top, but what is going on with the people in the areas they work, and if those mirror what the CEO has advocated.  Put another way, it’s a reminder that tone at the top is only important if it is mirrored by middle management and in day-to-day operations. Listen in to his podcast to learn more about these issues and what Gartner’s research has found when it comes to assessing and improving culture.  And, to hear more, be sure to attend his session “Advancing a Culture of Integrity by Building Strong Climates” at the 2018 Compliance and Ethics Institute.

 Sabine Fercher on ISO 19600 for Compliance Programs [Podcast] | File Type: audio/mpeg | Duration: 10:54

By Adam Turteltaub While at the 2018 SCCE Basic Compliance and Ethics Academy in Singapore I had the good fortune to meet Sabine Fercher, the Group Head of Compliance for Avaloq, a provider of IT solutions for the banking industry.  She was attending the Academy with several of her colleagues from around the world. Sabine is an advocate for ISO 19600, which is a standard for compliance programs.  Unlike the better known and oft-discussed ISO Standard 36001 for anti-corruption programs, 19600 is not a standard companies are certified against.  Instead it “provides guidance for establishing, developing, implementing, evaluating, maintaining and improving an effective and responsive compliance management system within an organization.” As Sabine explains in the podcast, work on this standard goes back many years.  It was designed to be used by companies and organizations from a wide range of industries. Listen in as she explains what it covers, what it emphasizes, how it should be used, and how it shouldn’t.

 Michael Horowitz on Conducting High Profile Internal Investigations Part 2 [Podcast] | File Type: audio/mpeg | Duration: 21:15

By Adam Turteltaub As Inspector General at the US Department of Justice Michael Horowitz has been at the center of internal investigations the scope of which few in compliance will ever see.  But, while it’s unlike a compliance officer will face the over 1.2 million documents Michael’s team waded through as part of the review of the FBI’s handling of the Clinton email investigation, there is more in common than one would think. In Part 2 of this two-part podcast Michael addresses issues that would look familiar to any compliance officer who is familiar with investigations: * Determining who should be included in the investigations * Maintaining confidentiality * The importance of process * Keeping at bay individuals who want to know what the investigation is finding before the investigation has concluded * When information should be disclosed before the investigation is concluded * Writing the investigation report, including keeping things mundane (and shared an anecdote that came from a Bob Woodward speech) * Sharing the findings with leadership * Learning from the process Listen in to gain some of his wisdom.  One warning, though, before you do.  If you are listening to these podcasts hoping for fresh insights into the Clinton email investigation or any other of the IG ’s investigations, you will be disappointed.  Our goal is to take a look at the investigations he has led from the perspective of a compliance officer and to benefit from his very deep experience conducting large scale, high profile investigations. You can listen to Part 1 here:

 Michael Horowitz on Conducting High Profile Internal Investigations Part 1 [Podcast] | File Type: audio/mpeg | Duration: 32:34

By Adam Turteltaub Conducting an internal investigation is never an easy task.  Doing so with the President, Attorney General, Congress, the press and public all watching is even more difficult. Michael Horowitz lives that reality each day.  He has served as the Inspector General at the US Department of Justice since April 2012.  He also serves as Chair of the Council of the Inspectors General on Integrity and Efficiency, an organization comprised of all 73 federal Inspectors General. The Inspectors General community is currently celebrating its 40th anniversary and it posts the results of its investigations online. During his time as the IG at the Department of Justice, Michael has led a myriad of investigations and at two which have grabbed headlines:  Fast and Furious as well as the FBI’s handling of the Clinton email investigation. While the focus of those investigations is far removed from what most compliance professionals face, the process of the investigations would likely look familiar to any compliance officer.  That’s something Michael knows first hand, having conducted several investigations as outside counsel for multinational companies. In a two-part podcast, we gain Michael’s deep and extraordinary insights into how to conduct an investigation fairly and thoroughly, whether you are in the media spotlight, or toiling away quietly in an organization. In part one he discusses: * The history of the IG’s office: its history, role, and responsibilities * How to set objectives for the investigation * How to begin the investigation * The challenges of staying on task and avoiding mission creep * Collecting documentary evidence * Conducting interviews Listen in to gain some of his wisdom.  One warning, though, before you do.  If you are listening to this podcast hoping for fresh insights into the Clinton email investigation or any other of the IG’s  investigations, you will be disappointed.  Our goal is to take a look at the investigations he has led from the perspective of a compliance officer and to benefit from his deep experience in conducting large scale, high profile investigations.

 Susan Bounds on Transforming Your Compliance Training [Podcast] | File Type: audio/mpeg | Duration: 12:47

By Adam Turteltaub With a recently revised and much abbreviated Code of Business Conduct, the compliance department at AT&T saw an opportunity. In the past, explained Susan Bounds, who is Director, Compliance at the company, the model had been to train everyone, everywhere every year with a great deal of web-based training.  There were individual courses on every topic, which made for a lot of clicking through web pages for employees.  The company realized it was hard to maintain employee interest, and it was time to do something different. As Susan reveals in the podcast, they decided to shake things up to reflect the updated Code but also a much more mobile workforce. Their strategy was to develop new training that was more of an ongoing tool, not something to click through once and then put away.  The new training had to be interactive, more engaging, and more accessible for their workers. They also looked beyond the web, adding live training and traveling to fifteen different locations to offer it. Listen in to learn what they did, how it’s working and how the new training better enabled them to track learning and strengthen their compliance program. And, to hear more, plan on attending her session at the 2018 Compliance & Ethics Institute.

 Gabe Imperato on The Board’s Compliance Oversight Responsibilities [Podcast] | File Type: audio/mpeg | Duration: 13:14

By Adam Turteltaub The relationship between the board of directors and the compliance team is both an important and still-developing one.  Approximately half of compliance departments report directly to the board, a recent survey of the Society of Corporate Compliance and Ethics and Health Care Compliance Association revealed. Having a strong relationship is increasingly important, according to Gabe Imperato, a past president of the SCCE and HCCA, who serves as the managing partner in the Fort Lauderdale office of the law firm Nelson Mullins Broad & Cassell.  The US government has grown more specific about requirements for boards when it comes to oversight of compliance programs.  There is direction in the US Sentencing Guidelines and the DOJ Fraud Section’s compliance program evaluation questions.  There is also strong direction in settlements, frequently calling for greater board involvement in compliance. In this podcast Gabe discusses what compliance officers should be reporting to the board, what they should be asking from the board, and how to get a board that still doesn’t get it to understand the importance of compliance. Listen in to learn more, and start thinking about whether you should bring a member of your board to the upcoming SCCE Board Audit Committee Compliance Conference.

 Kim Brandt on What’s New at CMS [Podcast] | File Type: audio/mpeg | Duration: 7:03

By Adam Turteltaub Kim Brandt is a familiar voice and face for the compliance community, having worked at both CMS and in the Senate for well over a decade.  Currently she serves as the Principal Deputy Administrator for Policy and Operations at the Centers for Medicare & Medicaid Services (CMS). In this podcast she shares the latest on what CMS is doing and what compliance professionals need to consider. Listen in as she shares: * The emphasis on patients over paperwork * CMS’s efforts to reduce the regularly burden, which has already led to a 20% decrease in new manual pages * New, simplified documentation requirements * Revised proof of delivery requirements * How CMS is meeting the opioid epidemic * A focus on targeted probes and education * A new emphasis on outreach to and hearing from the provider community, including an RFI on Stark Law.

 Amii Barnard-Bahn on Working with HR [Podcast] | File Type: audio/mpeg | Duration: 14:19

By Adam Turteltaub Compliance can’t and doesn’t go it alone in an organization, even though at times it can be a very lonely job.  Legal, audit and HR are all essential partners. Amii Barnard-Bahn, an executive coach and leadership consultant knows this well from a career which has included extensive work in both HR and compliance.  As she explains in this Compliance Perspectives podcast, one of the challenges in the relationship between compliance and HR is that the two sides often don’t appreciate how alike they are.  They share many of the same challenges in gaining sufficient resources and getting a seat at the table. At the same time, there are substantial differences between the two.  Compliance is just a part of the areas that HR focuses on, and the two departments have overlapping but different mandates.  In addition, often the personalities of compliance and HR personnel are different, she believes. To help overcome the differences and work together more closely, each has to have empathy for the other and build trust.  That means compliance should invest, for example, in taking the time to understand HR, much like they take the time to learn the business. To learn more about how to build a successful relationship with HR, take a few moments to listen to Amii’s thoughts.

 David Wright on Compliance and Children Online [Podcast] | File Type: audio/mpeg | Duration: 16:39

By Adam Turteltaub Much of the attention paid to the European General Data Protection Regulation (GDPR) and its impact for online marketing has been focused on safeguarding data, disclosing cookies and email communications with customers.  But, that’s not all there is to it. As David Wright, the Director of the UK Safer Internet Center explains, the GDPR has a number of specific provisions that affect interactions between businesses and children.  And while the GDPR provides pan-European directives, it leaves room for state by state variations.  That makes living up to its requirements a bit more challenging for compliance teams. Making matters more complex, the GDPR isn’t the only new law to worry about.  The UK government is likely to introduce additional legislation designed to safeguard children. To better understand the challenge and what the compliance team needs to think about for everything from age verification to terms and conditions, spend some time listening to this podcast.  Then, if you’re interested in downloading the UK government’s guidance on children’s safety online that David refers to in the podcast, simply follow this link.

 Louis Perold on Compliance Challenges in Africa [Podcast] | File Type: audio/mpeg | Duration: 8:50

By Adam Turteltaub SCCE International Academy faculty member Louis Perold is based in South Africa, where he is a compliance officer for Jabil.  From there he has a unique perspective on the compliance challenges facing his home country and all of Africa. While the two of us were in Singapore for the Academy there, Louis took time away to share what is going on across the continent.  Listen in as he discusses: * The rising importance and challenges of privacy regimes * Ongoing issues in anti-corruption * The difficulties of implementing First World requirements in Third World environments * Working in an environment of constant change * The need to understand the local political environment, laws and customs

 Louis Perold on Compliance Infrastructure [Podcast] | File Type: audio/mpeg | Duration: 11:20

By Adam Turteltaub Louis Perold of Jabil is a member of the faculty for the SCCE International Basic Compliance and Ethics Academies.  One of the topics he addresses there is compliance infrastructure.  It’s a nuts and bolts session that lays the foundation for compliance work. On this podcast, Louis takes us through the steps for creating the right infrastructure (hint:  start with the seven elements and then secure board buy in).  From there he explains what to look for in your staff as well as skills you can “borrow” from other departments.  And, finally, he addresses what to think about as your program grows, managing costs, and how you can better align your compliance program with the business, including keeping the support of leadership. Listen in to ensure your compliance program is resting on the right foundation.

 Kerry Contini on Trade Sanctions [Podcast] | File Type: audio/mpeg | Duration: 14:28

By Adam Turteltaub When assessing global compliance risks, anti-corruption issues tend to grab the headlines, but they are far from the only concern.  Trade sanctions, which are risk with complexity can be an enormous challenge for organizations. Kerry Contini, a partner in the Washington, DC office of the firm Baker McKenzie explains in this podcast that there are three kinds of sanctions:  embargoes, targeted, and restricted parties.  Embargoes are the simplest to understand since entire countries, such as Cuba and North Korea, are included.  But, beyond that, it gets more complicated, requiring companies to know who the individuals are in a deal that they are doing. If a Specially Designated National (SDN) owns more than 50% of a company, then it could be illegal for you to sell to it.  That’s a challenge since it’s not easy to get that ownership information, given opaque business structures, especially in a country like Russia. Likewise, a sale may not be permissible if the destination of the goods sold is a place like Crimea, or if the goods are intended for certain energy projects. Listen in to the podcast to better understand the pitfalls of trade sanctions, and how you can better manage this dangerous compliance risk area.

 Gail Peace on Why Managing Physician Contracts is Like a Game of Whack a Mole [Podcast] | File Type: audio/mpeg | Duration: 11:48

By Adam Turteltaub Most everything related to healthcare compliance quickly grows complex, including physician payments.  While it would seem simple, each payment brings waves of complexity, with some organizations having more than a dozen steps in the process. As Ludi President Gail Peace explains, it’s not surprising.  Stark Law and Anti-Kickback are complex, and there has been an uptick in individual prosecutions since the Yates memo. It behooves organizations, she argues, to start thinking proactively and look at their processes, structure and accountability when it comes to physician payments.  This includes: * Looking at Lean Six Sigma to streamline efforts and remove unnecessary costs * Considering a physician spend management department * Recognizing that the physician contract is but the start of the process Listen in to learn more about how to manage the complexity of physician payments.


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