Two cases illustrate some of the problems with the use of outside counsel for internal investigations. The possibility that a conflict of interest could arise when an attorney or law firm simultaneously represents an organization and one or more of its officers or directors is a recurring issue. A ruling earlier this month by U.S. District [...]
Archive | April, 2009
2009 World’s Most Ethical Companies
Ethisphere has published its collection of 2009 World’s Most Ethical Companies. Twenty companies dropped off the 2008 list and 25 new ones were added, leaving a list of 99 companies. Who caught my eye was Jones Lang LaSalle, a real estate company (one of my company’s business relationships) who was back on the list again. [...]
What Can We Learn About Compliance Programs From a Robot
We all need some help if we want to get to our destination. I was struck by Kacie Kinzer’s experiment using this “tweenbot” in New York City. “Tweenbots are human-dependent robots that navigate the city with the help of pedestrians they encounter. Rolling at a constant speed, in a straight line, Tweenbots have a destination [...]
The 4 Ps of the Internet: Personal, Private, Professional, and Public
I often hear the challenge of using the social internet as struggling with the balance of social (or personal) information and professional information. This never seemed to frame the issues correctly for me. Was it really one or the other? So I started thinking about the 4 Ps: Personal, Private, Professional, and Public. These seemed [...]
Corresponding with Cornelius – a new series of blog posts
Not all of my online conversations take place here at Compliance Building. I try to make as many comments in other places as I do here. Twitter is a sporadic stream of thoughts, comments, and replies. I also try to leave as many comments on other blogs as I do posts here. I think you [...]
Carried Interest Tax Legislation
We saw in the Obama budget (A New Era of Responsibility) that the administration was looking to raise revenue by taxing the carried interest for private investment funds. I was waiting to see how that one line item in the budget might translate into actual legislation and a change in tax policy. Congressman Sandy Levin [...]
Document Behaviors
A version of this post originally appeared in my old blog: KM Space. I have been focusing a lot of attention on the behaviors towards documents. After all, a wiki page is just another type of document. When producing documents, I have noted five types of behaviors: collaborative, accretive, iterative, competitive and adversarial. Collaborative With [...]
Breaking Down Compliance Silos: The Cost-Effective Approach to Managing Compliance
Michael Rasmussen, President of Corporate Integrity, Julian Parkin, Group Privacy Programme Director at Barclays, and John Kelly, Director at OpenPages, spoke in a webinar on taking a strategic approach to managing compliance. The webinar was sponsored by Compliance Week. These are my notes. Michael set the stage by asking: Does your organization walk its talk? [...]
Whistleblower Programs: Challenges for Multinational Companies
Katherine D. Ashley, Gary DiBianco, Dana H. Freyer, Matthias Horbach, Pierre Servan-Schreiber of Skadden, Arps, Slate, Meagher & Flom LLP put together a nice article addressing the challenges of exporting the whistleblower requirements under Section 301 of Sarbanes-Oxley to operations in the European Union: Whistleblower Programs: Challenges for Multinational Companies. Section 301 of the Sarbanes-Oxley [...]
IRS Issues New Guidance on COBRA Subsidy
The Internal Revenue Service has issued Notice 2009-27 (.pdf), providing new guidance relating to the COBRA subsidy made available under the American Recovery and Reinvestment Act of 2009. Notice 2009-27 provides guidance on the definition of involuntary termination and assistance eligible individual. It also provides more detail on calculating the subsidy and determining the election [...]
Social Media
My social media policies database is available to you.
Affilate
This website uses the Canvas Wordpress theme from WooThemes. (affiliate link)
