Over the past few months, the OIG shorts series focused on structuring and implementing a comprehensive and effective ethics and compliance program. Many times, this requires a mindset shift from a checking-the-box mentality to a wholistic approach in which everyone feels they have an important role to play. Nowhere is this more apropos than in the area of cybersecurity including developing a data security strategy and maintaining an effective incident response plan.
This blog was originally published in Law360.
On November 18, 2022, U.S. District Court Judge Edward Davila sentenced Theranos founder and CEO Elizabeth Holmes to over 11 years in…Continue Reading When Organizational Culture Goes Wrong: A Federal Judge’s Vivid Description of Cultural Decay Inside Theranos
There is a compliance obligation that is sometimes honored in the breach: regular compliance self‐assessments. In this edition of OIG Shorts, the Sheppard Mullin Richter & Hampton LLP Organizational Integrity…Continue Reading Organizational Integrity Shorts: Compliance Self-Assessments
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 Funding
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 Program
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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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 Matters
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
Welcome back to our second installment of OIG Shorts. In this post, the Sheppard Mullin Richter & Hampton LLP Organizational Integrity Group focuses on the difference between Checking Boxes and…Continue Reading Organizational Integrity Shorts: Everyone Benefits When An Ethics & Compliance Program Is Integrated Throughout An Organization
Over the course of the next few months, the Sheppard Mullin Organizational Integrity Group will be exploring a number of complex compliance matters in a series we call “OIG Shorts.”…
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