FCPA COMPLIANCE REPORT-EPISODE 382, SUSAN DIVERS ON LRN’S 2018 PROGRAM EFFECTIVENESS REPORT

May 9, 2018 LRN Corporation

Recorded on April 17, 2018

In this episode Susan Divers, Senior Advisor at LRN, returns to talk about LRN’s 2018 Program Effectiveness Report, which demonstrates that programs focused on values outperform those based primarily on checklists and rules. Divers believes this has only become more important in the wake of the #MeToo movement and as sexual harassment scandals continue to erupt.

As Susan reveals in the podcast, the most effective E&C programs—and the ones that are better able to meet the 2017 DOJ criteria—do the following:

  • “Operationalize” ethics and compliance using principles and values that inform all organizational decisions, not just those made in a legal or regulatory context.
  • Ensure that the company analyzes the root cause of misconduct, rather than simply punishing misconduct.
  • Embrace accountability and transparency – even if it means holding senior leaders or successful performers fully accountable for their actions.
  • Make sure senior leaders, middle managers and boards of directors are engaged in preventing misconduct, and that the function isn’t left exclusively to lawyers or compliance staff.
  • Are continuously reviewed and improved to ensure they remain value-focused and effective in terms of influencing workplace behavior in a positive way.

Click here to listen to the podcast.

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