The first article was on Three trends regarding the costs of ineffective compliance. Jeff first focused on the increasing occurrence of the “mega fine.” Then noted that desperate times tend to breed desperate deeds. Lastly he noted that the new attorney-general is the same official who set compliance and ethics standards as part of the DOJ’s enforcement decisions.
The second article was on non-costly ways to achieve C&E program successes. Jeff noted that it is more cost-efficient to build the compliance assessment into other functions.
The third article focused on how to embed risk assessment into the process of drafting “third-party” codes of conduct. Jeff points out that handing your employee to third parties will just lead to confusion. In drafting a code, make sure you elicit comments from the people in the company with direct third party dealings.