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Toyota, Ethics and Compliance

With Toyota’s problems all over the news, I started to think about whether compliance and ethics professionals could learn anything from these problems. To begin, I don’t think there is a systemic problem with their vehicles or with the company. I think the sudden acceleration problem is bunk. Yes, I own a Toyota, but my [...]

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New Codes of Conduct for Real Estate Companies

It’s always useful to look at what your competition is doing. The same is true in drafting your code of conduct (or code of ethics or whatever name you chose). It is useful to look at you what your competitors’ codes of conduct look like. Since Sarbanes-Oxley requires a public company to have a code [...]

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Massachusetts Amends Its Strict Data Privacy Law (Yet, Again)

Massachusetts Amends Its Strict Data Privacy Law (Yet, Again)

Massachusetts has revised its data privacy regulations one more time. The revised regulations are less demanding that the original version released over a year ago. But this law is the strictest in the country and will be the de facto law of the land for many companies. Office of Consumer Affairs and Business Regulation released [...]

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Compliance, Van Halen and Brown M&M’s

You may have heard the story about Van Halen’s banning of brown M&M’s from its dressing room. I chalked it up to the pampered life of rock stars. (Especially, when compared to the more mundane life of a chief compliance officer.) I just listened to the latest episode of  This American Life which revealed that [...]

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Workplace Computer Policy and the Attorney Client Privilege

Workplace Computer Policy and the Attorney Client Privilege

Back in April, I mentioned a New Jersey case that found e-mail, sent during work hours on a company computer, was not protected by the attorney-client privilege: Compliance Policies and Email (Stengart v. Loving Care [.pdf]) That case has now been overturned. It seems that a company’s policy on computer use may be more limited [...]

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Attorney-Client Privilege and Internal Investigations

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 [...]

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Compliance and Recommendations on Social Networking Sites

Compliance and Recommendations on Social Networking Sites

I am an enthusiast of social networking sites and web 2.0. But I realize they have limitations and dangers. I have been very concerned about the Recommendations feature in LinkedIn. That feature allows any of your connections on LinkedIn to post a recommendation or endorsement about you that appears on your profile page. At first, [...]

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Corporate Compliance Fraud in Georgia, Florida and Massachusetts

Just like the Corporate Compliance Fraud in Ohio, Compliance Services is also targeting companies in Georgia, Florida and Massachusetts. The Daily Citizen is reporting Georgia corporations warned about solicitations. The Georgia Secretary of State issued a warning: “Several corporations registered with the Corporations Division of the Office of the Secretary of State received a letter [...]

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