Aristotle said “well begun is half done.” About 2,300 years later, Mary Poppins shared the same advice with her young charges, Jane and Michael. The adage generally is understood to mean that a thoughtful and disciplined start puts a project in a good position for success. With apologies to Aristotle (and Mary), the members of Sheppard Mullin’s Organizational Integrity Group use the same adage as a warning. In our experience, well begun is only half the battle. This month’s OIG Shorts discusses the importance of the activities that take place toward the end of — or after — an internal investigation or other response to an organizational crises.Continue Reading Organizational Integrity Shorts: The Importance of Post-Investigation Activities
Jonathan Aronie
Jonathan Aronie is the Leader of the firm's Governmental Practice Group and is a former Managing Partner of the Washington, D.C. office. Jonathan also is a founding member of the firm's Organizational Integrity Group, a cross-disciplinary team of litigators, regulatory specialists, federal monitors, and ex-prosecutors with extensive experience helping organizations prevent and defend against challenges to their organizational integrity.
Organizational Integrity Shorts: Good Plans that go Awry or why we Conflate Bad Outcomes with Bad Decisions
The research is clear. A good decision with a bad outcome is likely to be viewed – by others and by the decision-makers themselves – as a bad decision in…
Continue Reading Organizational Integrity Shorts: Good Plans that go Awry or why we Conflate Bad Outcomes with Bad DecisionsOrganizational Integrity Shorts: Don’t Just Let the Dominoes Fall; Understand the Paths They Might Take
Let’s say you’re a publicly traded manufacturer of a popular medical device, which you sell commercially as well as to a number of VA hospitals. You receive an anonymous internal hotline complaint alleging that certain unauthorized, reverse-engineered components were used in the manufacturing process and that certain quality tests were skipped in the interest of “efficiency.” You triage the complaint, do your preliminary diligence, determine the complaint isn’t frivolous, and launch a privileged internal investigation.Continue Reading Organizational Integrity Shorts: Don’t Just Let the Dominoes Fall; Understand the Paths They Might Take
Organizational Integrity Shorts: The Science of Persuasion
Too often people argue as though they are in front of a judge, or some other cosmic arbiter of correctness, rather than asking ourselves what might move our opponent. In this edition of OIG Shorts, the Sheppard Mullin Richter & Hampton LLP Organizational Integrity Group explains that to increase our chances of moving our opponent, we need to recalibrate our goals, rethink our strategy, and reframe the discussion.Continue Reading Organizational Integrity Shorts: The Science of Persuasion
Organizational Integrity Shorts: A Seat at the Table
In the 10th edition of the “OIG Shorts” series, Sheppard Mullin’s Organizational Integrity Group continues its exploration of a number of complex compliance matters with a discussion on Setting the Table for Good Decision-Making: And Making Sure the Chief Legal Officer Has a Seat at It. This post discusses why it’s important that Chief Legal Officers and Chief Ethics & Compliance Officers have meaningful, real-time involvement in the key legal, organizational, reputational, and business discussions/decisions of their companies, as well as direct access to the Chief Executive Officer and the Board.Continue Reading Organizational Integrity Shorts: A Seat at the Table
Organizational Integrity Shorts: Understanding the Various Layers of a Targeted Compliance Program
This month, Sheppard Mullin’s Organizational Integrity Group continued its exploration of a number of complex compliance matters as part of their “OIG Shorts” series with a discussion on Understanding the Various Layers of a Targeted Compliance Program. This post discusses the importance of a targeted, multi-layered compliance program focused at individual deals, sales, contracts, etc. – as distinguished from the equally important company-wide E&C program previously discussed.Continue Reading Organizational Integrity Shorts: Understanding the Various Layers of a Targeted Compliance Program
Organizational Integrity Shorts: Ethics & Compliance Program Funding
Many business leaders still view Ethics & Compliance as a cost center rather than a cost reducer. This thinking can create quite the hurdle for CECOs looking to secure a…
Continue Reading Organizational Integrity Shorts: Ethics & Compliance Program FundingOrganizational Integrity Shorts: Measuring The Efficacy Of Your Ethics & Compliance Program
Previous installments of OIG Shorts addressed practical approaches to creating a more effective Ethics & Compliance program. The sixth installment of OIG Shorts focuses on the importance of measuring the…
Continue Reading Organizational Integrity Shorts: Measuring The Efficacy Of Your Ethics & Compliance ProgramOrganizational Integrity Shorts: Let’s Be Disciplined About Discipline
Discipline is a complicated thing. Ask any parent. The fifth installment of OIG Shorts focuses on discipline as a core component of an effective Ethics & Compliance Program.
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Continue Reading Organizational Integrity Shorts: Let’s Be Disciplined About DisciplineOrganizational Integrity Shorts: Structure Matters
In our decades working with complex organizations on their Ethics & Compliance (E&C) programs, my colleagues and I have seen a wide variety of structures. While we readily concede there…
Continue Reading Organizational Integrity Shorts: Structure MattersOrganizational Integrity Shorts: Reality Based Ethics & Compliance Programs
Welcome to our third installment of OIG Shorts. Ethics & Compliance programs that buck up against an employee’s reality—whether that reality is real or perceived—have less chance of succeeding. In…
Continue Reading Organizational Integrity Shorts: Reality Based Ethics & Compliance Programs