Compliance &Ethics - Society of Corporate Compliance and Ethics

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Featurecannon and will eventually slip up and sabotagethemselves, just before throwing youunder the bus.Second, vendors may think that influencingbuyers is a necessary reality in order to becompetitive. Ethics and compliance operativesshould be aware that inappropriate vendorinfluence is not always blatant and easy to spot.Here are some examples of promo and entertainmentexpenses that may be overlooked bycorporate ethics and compliance folks:··Sponsoring a Little League or softballsports team or other charitable cause··Lunch or dinner··Drinks—a vendor may rationalize,“How many times have I bought strangersa drink (and who cares)”··A birthday or holiday card and gift sent tothe buyer’s home··Sports or concert tickets left at the will-callwindow··A complimentary visit to the vendor’svacation home at the beach or in themountainsCorporations that staff a “buyer/acquisitions”department need to be cautious abouttheir rules and how compliance is verified andenforced. Compliance alone is not the end all.Ethics and compliance must be promoted on apersonal level. All ethics is personal. It standswith one person and can fall with one person. ✵Peter Crosa is a philosophizing private detective out of Tampa Bay, Florida.His keynote speeches bring humor and motivation to E & C divisions andassociations. He can be reached at peter@ethics-speaker.com.2012 Compliance & ETHICS INSTITUTE PREVIEWCompliance & Ethics Professional May/June 2012session 303: A Case Study of the Ethical (and Not-So-Ethical) DecisionsLeading to the 1986 Challenger TragedyMonday, October 15, 2012, 3:00 Pm – 4:00 pmKendra Cook, IntegrityApplications IncorporatedIn the competitive environment in which weoperate, engineers and their managers are put ina position to make critical ethical decisions withserious consequences. Trade-offs must be made in order to meet design and performancerequirements while completing the project within a given budget and time frame, allwithout jeopardizing the safety of the users. This session illustrates the complexities ofmaking ethical decisions using the 1986 space shuttle Challenger tragedy as a case study.Attend SCCE’s 11th Annual Compliance & Ethics Institute in Las Vegas, NV,to hear more! Visit www.complianceethicsinstitute.org for more information.32 www.corporatecompliance.org +1 952 933 4977 or 888 277 4977
View from the Front Linesby Meric Craig Bloch, CCEP, CFE, PCI, LPIAre you in control of yourinvestigation?BlochWhen a serious allegation of misconductarises, the business peopleinvolved simultaneously react toa number of concerns. There is the implicatedemployee who was previously in a positionof trust. There may be an unhappy customerwho now has a “crisis of confidence”in your company’s ability to perform.There may be executives whom thebusiness people fear will blame themfor allowing the problem to happen.The implicated employee may be asales superstar whom the departmentmanagers fear losing to the competition.These factors usually lead to businesspeople trying to steer the investigationtowards their particular goals and away fromtheir professional fears.Ownership of an investigation comesfrom the pride that is taken in conductingthe most complete and objective review thatis professionally possible. Ownership comesfrom adhering to a set of guidelines and principles,rather than politics and situations. Theultimate objective of an investigation is a fullinquiry that is not motivated by politics, personality,or expediency.These principles can be tested when theurgencies of a critical situation arise, butadhering to them becomes more importantthan ever. Establish your role at the outset asthe “quarterback” of the investigation. Leaveno doubt with your colleagues that the companyplaces the investigative responsibility onyou. Whatever their motives are for wantingto take such an active role, it is you, not they,who remain accountable to the company for asuccessful, professional, and proficient investigation.Investigation-by-committee simplydoes not work.When people seem to be interfering withyour investigation, ask yourself why thesepeople seek an active role. You’ll quicklyfind that their motives are understandableand usually practical. They are likely motivatedby a fear of what the investigation willshow and how they may be blamed by theirsuperiors. If this happens, don’t get into awrestling match with them about the investigation.Instead, explore why they feel theyneed such an assertive role instead of justbeing the customer of your efforts. You mayfind you can accommodate their needs fairlyeasily, and they will step aside and let you doyour job.There is room in the investigative processfor others to participate. Indeed, this is the bestway to keep it business-focused—but it is you,not they, who have the training and responsibilityfor completing a proficient investigation.Solicit their needs and concerns, and then doyour best to respond to their priorities. Helpwhere you can. Make sure you understandtheir post-investigation needs. But you haveto set the strategy and decide what has to bedone to complete the investigation. You ownthe process and its outcome. ✵Meric Craig Bloch is the Compliance Officer for the North Americandivisions of Adecco SA, a Fortune Global 500 company with over 8,000employees and $6 billion in annual revenue in North America. He hasconducted more than 300 workplace investigations of fraud and seriousworkplace misconduct. He is an author and a frequent public speaker on theworkplace investigations process. Follow Meric on Twitter @fraudinvestig8r.Compliance & Ethics Professional May/June 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 33
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