Organizational integrity

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

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

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

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

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

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.Continue Reading Ethics & Compliance: Let’s Talk About Cybersecurity