• Survive and Thrive

  • By: Tom Fox
  • Podcast

Survive and Thrive

By: Tom Fox
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  • Summary

  • Welcome to Survive and Thrive where Tom Fox and Kortney Nordrum are talking about the compliance disasters which befell companies because they weren’t looking at the right clues, had their heads in the sand or failed to expect the unexpected. If you want to know how to prepare for and avoid disasters from the compliance perspective, this is the series for you. 
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Episodes
  • How To Survive A Corporate Social Media Disaster

    How To Survive A Corporate Social Media Disaster
    Sep 7 2021
    It's just a typical day as CCO. You're sitting at your desk having lunch and checking your email and social media. You notice that your company name is trending on Twitter, and you think it strange that there aren't any new company announcements or products launching. You go to Twitter and realize that you are trending for all the wrong reasons – someone on your corporate social media team has made a big mistake.  How do you survive a corporate social media disaster?  Key points discussed in the episode: ✔️ The first step is talking the CEO off a ledge. While social media disasters are…disasters… they are also fleeting. Unless we made the world's biggest social media mistake, we are likely to be replaced in the news cycle with someone else making a similar mistake in days, not weeks. ✔️ Connect with the Comms and Marketing team - whichever runs our social media. Work to determine next steps like removing the post or print retraction or apology, mea culpa etc. ✔️ Once the urgency subsides, it is time for a root cause analysis – what happened (or didn't happen) that allowed this situation?  ✔️ Do we have a social media policy? Is that policy written to apply to the departments using social media on behalf of the organization, or does it only apply to employees who may use social media personally? ✔️ As CCO, ensure that the policy speaks to the right audience and use concrete examples of what is okay and what isn't. Your efforts all go out the window if the organization isn't training how to make the choices people need to make and do the things they need to do. ✔️ Part of the training should include who to call for help. The social media comms/marketing team should have proactively reached out for help or advice.  ✔️ Social media is entertaining, but it needs to be taken seriously, particularly at a corporate level. As the adage goes, an ounce of prevention is worth a pound of cure— so must your goal be in keeping social media disasters at bay for your company. Teach your organization your expectations of how social media interaction should work and what their responsibilities are.  ---------------------------------------------------------------------------- Welcome to SURVIVE AND THRIVE, this is a podcast where we unpack compliance, crisis disasters and walk you through all the red flags which appear, and give you some lessons learned going forward. This show is hosted by Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation.  Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.
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    24 mins
  • Gifts, Travel, and Entertainment

    Gifts, Travel, and Entertainment
    Aug 31 2021
    The FCPA world is littered with enforcement actions against companies for the most basic compliance failures – those around gifts, travel, and entertainment (GTE). Many compliance professionals struggle with issues from GTE: Violations can arise out of anything, from discrepancies between outbound and inbound reporting to simply relying too heavily on the manual process of maintaining spreadsheets. As your company is considering RTW sometime in fall 2021, you know you will need to remind everyone about why GTE is so critical to compliance. How do you add in an analysis of more efficient business travel, time use, and even whether you need to travel for meetings? Key points discussed in the episode: ✔️The Gifts, Travel, and Entertainment (GTE) Policy is foundational to a company's values. GTE touches so many other pieces in a compliance program – COI, anti-corruption, anti-fraud, government contracting, donations/corporate giving, marketing in the healthcare space, etc. Small numbers are essential, and telling the truth about GTE reimbursement is critical to an ethical culture.    ✔️Each company has different GTE rules in place – first, you have to take stock of what rules apply to your company and your sales force.  ✔️ Look at who you do business with? If your customers are all state governments, that makes it easy – no gifts or entertainment, ever—however, companies operating in several markets may have varying customers. Be aware of what your customers can and cannot accept re: GTE. ✔️ In your organization, build a policy that speaks to your specific obligations. Make it clear that every single gift or entertainment expense must be documented and submitted, and nothing is off-books.  ✔️ Include as many examples as possible in your policy – call out specific things that are not allowed (aka DO NOT GIVE ANYONE A FERRARI OR A HOUSE IN THE HAMPTONS…OR A CONGRESSIONAL SEAT).  ✔️ Make things much more concrete and give people an idea of what's appropriate and not appropriate. It is essential to call out cash and cash equivalents to explain better why It is NEVER okay to give cash or equivalents as GTE.  ✔️ Train the heck out of the policy – both the broad workforce and the finance team that will be reviewing the invoices and the sales team that will be incurring the expenses. Walk them through expectations and what to watch out for as red flags. ✔️ Use checklists – give the team reviewing invoices a list of what to look for (good and bad) and have them do it (formally or informally) for each invoice.  ---------------------------------------------------------------------------- Welcome to SURVIVE AND THRIVE, the newest addition to the Compliance Podcast Network. This is a podcast where we unpack compliance, crisis disasters and walk you through all the red flags which appear, and give you some lessons learned going forward. This show is hosted by Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation.  Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.
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    28 mins
  • Creating and Maintaining a Speak Up Culture

    Creating and Maintaining a Speak Up Culture
    Aug 24 2021
    Companies with more internal reports and complaints benefit from lesser problems occurring inside. In his paper, Dr. Kyle Welch shared that overall litigation settlements of non-material matters dropped almost 20% over three years as well. It is, therefore, made clear that speak up culture is not simply about compliance and violations but building up the trust that it is safe to raise your hand and express concerns and give feedback. Key points discussed in the episode: ✔️ Speak up culture is built on trust. Employees must trust that when they report wrongdoing, or potential misconduct, that those reports will be investigated and, if needed, actions will be taken. Without this trust, speak up culture is a pipe dream.  ✔️ There is a disconnect between the employees on the front line and the senior management in most organizations; therefore, trust is part of the psychological safety that we all must work to create. Whistleblower policies and generic communications about hotlines are not good enough.  ✔️ The middle managers are going to be the most influential culture builders in your organization. Create a model of engagement with middle managers – and engage with them. Hold town hall sessions, encourage transparency, and listen regularly. Remember, the flow of information and cadence is important.  ✔️ Include as many ways as possible for people to reach out and speak up – formally and informally. Hotlines tend to be a "last resort," and employees use them when they've exhausted other options. Let's create opportunities to have concerns addressed faster and possibly less formally.  ✔️ Be proactive – ask for feedback, concerns, and complaints. Open the lines of communication, so when there is something to report, it is already second nature for employees to report it. ✔️ Take concerns seriously and have a high say-do ratio. The basis for speak up culture is that we want employees to raise concerns. That means when they raise those concerns, we must do our part and act on them. Employees need to see things change as a result of their speaking up.  ✔️ Make sure you have a clear anti-retaliation policy and that employees reporting concerns in good faith are not retaliated against.  ---------------------------------------------------------------------------- Welcome to SURVIVE AND THRIVE, the newest addition to the Compliance Podcast Network. This is a podcast where we unpack compliance, crisis disasters and walk you through all the red flags which appear, and give you some lessons learned going forward. This show is hosted by Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation.  Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.
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    17 mins

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