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Joseph Jay is a white collar defense and government investigations partner in the firm's Washington, D.C. office.

The inattention some companies pay to their ethics and compliance program never ceases to surprise us. You’d think the frequency of DOJ press releases and prosecutions holding companies accountable for employee wrongdoing would be enough to scare any business into directing more resources at prevention. But alas, many businesses, often over the protestations of their under-resourced Chief Ethics and Compliance Officers (CECOs), continue to think they can get by with a minimalist approach to ethics and compliance. Our experience suggests otherwise.
Continue Reading DOJ’s Renewed Focus On Corporate Ethics & Compliance Programs Highlights Importance Of Organizational Integrity

The University of Kentucky (“UK”) announced that it had fired all the coaches of its powerhouse cheerleading team on May 18, 2020 after a three-month internal investigations into allegations of hazing, public nudity, lewd chants, and alcohol use among team members over a number of years.  UK released an eight-page internal report by its Institutional Equity and Equal Opportunity office that probed, among other things, whether “the coaches . . . knew of or should have known” about misconduct by team members and concluded that the “weight of the information provided is sufficient to establish that the coaching staff were aware or reasonably should have been.”
Continue Reading (Cheer)Leading By Example: UK’s Cheerleading Scandal and Lessons for Leaders

I was sitting in my office last week thumbing through the latest issue of the Chronicle of Higher Education – the diary of news in the academe – and it hit me that story after story touched on what my colleagues and I call “organizational integrity.” Universities should increasingly focus on their integrity – their values, their culture, their own sense of right and wrong – as the bedrock of their organizational decision-making, risk management, and compliance. And, when their reputations are threatened,  universities should try to ground their response in those same values.
Continue Reading Universities Should Focus on Organizational Integrity in Wake of Scandals

Synopsis

The academic scandal that rocked the University of North Carolina from 2011 to 2014 epitomizes the need for decisive action to respond to circumstances that threaten an organization’s integrity. Failing to respond – or delaying such a response – can threaten an organization’s reputation for candor and transparency. Organizations must not react reflexively in these situations; rather, organizations must react in a way that bolsters or restores its integrity. And, where appropriate, organizations must accept responsibility, adopt and implement meaningful reforms, and transparently report what happened.
Continue Reading Managing a Crisis of Integrity: The University of North Carolina Academic Fraud Scandal