CONVERGE is in its 4th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Eric Feldman, SVP at Affiliated Monitors, Inc. and visit about his talk, the CCO’s Role in Performance Management that Drives Employee Behavior.
Employee incentives, bonuses, and promotions are all great motivators, right? Wrong! In this session Eric Feldman explains how an innocent incentive program can bring down a company. Perverse incentives are at the root of so many misconduct cases. Learn how you can play a value-added role in corporate performance management processes.
For more information on Converge19, click here.

As SEC Chair Jay Clayton scolds the rest of the world for its lack of anti-corruption enforcement and does say why he wants to dump a PCAOB Member, Tom and Jay are back  to discuss some of this week’s top compliance and ethics stories which caught their collective eyes.

  1. SEC Chair scolds weak overseas anti-corruption enforcement. Dave Micheal reports in the WSJ Risk and Compliance Journal.
  2. Why does SEC Chairman want to get rid of PCAOB member, Kathleen Hamm? Francine McKenna explores in MarketWatch.
  3. Fair Pay to Play? California pass law allowing college athletes to be compensated. Michael McCann reports in com.
  4. Did the SFO put in a ‘self-certification’ requirement in its recent Guidance on Cooperation? Aziz Rahman says yes in the FCPA Blog.
  5. How can independent integrity monitors help to limit adverse consequences in health care? Jay concludes his series on monitors in the health care industry in CCI.
  6. NYU PCCE gets new Executive Director as Alycin Cooley joins the group. NYU Compliance and Enforcement Blog.
  7. How can you process personal employee data under GDPR? Laura Wright, Sarah Greenwood and Andrew Reeves opine in the FCPA Blog.
  8. What happens when employees ethical values are greater than those shown by their employer? Michael Toebee explores in an interesting post on CCI.
  9. One commentator suggests we hold back on international enforcement against bribe-takers. Anton Moiseeineko writes in the FCPA Blog.
  10. Tom continues his preview of the Converge19 speakers in a special bonus series of podcasts on the Compliance Podcast Network. Check out the following: Monday-Ricardo Pellafone and Ashley Lewis on Building Your Brand; Tuesday-Michael Williamson on moving to a values based culture; Wednesday-Mike Volkov on the Nuts and Bolts of Sanctions Compliance; Thursday-Nicole Pitts on Increasing Employee Engagement and Friday– Eric Feldman on the CCO’s role in performance management. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube,  Spotifyand the Compliance Podcast Network.
  11. The Everything Compliance gang will be doing its first live podcast at Converge19. You should be there! Listeners to this podcast can obtain a complimentary ticket by using the promotion code foxvip, for registration and information, click here.

Tom Fox is the Compliance Evangelist and can be reached at Jay Rosen is Mr. Monitor and can be reached at For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at

This week, I am exploring some of the compliance service offerings I make available to the compliance community through my consulting company, Advanced Compliance Solutions. Today, I want to conclude this week’s services offerings with a discussion of why you should create a  Compliance Center of Excellence (CCoE)for your organization.

Why should you have a CCoE? Simply put, it would allow you to pair the top talent in your organization with some of the top compliance resources available in a structure which will drive your organization. A CCoE should have several different areas. First, it should offer support to the compliance function’s customer, company employees, third parties and others impacted by the corporate compliance function. It should provide support for those impacted by compliance in an organization by being a subject matter expert (SME) in the compliance arena. There should be guidance from the CCoE in compliance standards, methodologies and the CCoE should act as a compliance knowledge repository. A CCoE should provide shared learning, including compliance training and certifications, skill assessments, team building and formalized roles which are all ways to encourage shared learning. A CCoE should provide measurements, which demonstrate it is delivering the valued results that justified their creation through the use of output metrics. Finally, in the area of governance, a CCoE should allocate limited resources across all their possible uses, ensuring organizations invest in the most valuable projects and create economies of scale for their service offerings.

As with the compliance function in total, it should work with the business unit to design, create and implement a compliance solution that can be pushed out to more fully operationalize compliance. Mark Vaughn, author of the Navint Partners, LLC white paper, entitled “Financial Services: Compliance Center of Excellence”, noted that the CCoE team would “work to develop a roadmap based on careful planning and analysis, including understanding how, through scenario planning efforts, the organization will pivot one direction or another, to initially address regulatory compliance and improve it over time.”

It would allow compliance to be more integrated in planning and strategy discussions to stay tuned to the ever-changing risk profile of a company. Moreover, through this interdisciplinary approach, it would bring compliance knowhow to help the business folks understand that compliance is, in reality, a business process and as a business process, it can easily be incorporated into business unit operating procedures going forward.

A CCoE can become a very powerful tool for the compliance function in an organization. Compliance is properly seen as business process. If you integrate the compliance framework of controls, incentives, continuous information and its feedback into your company’s business process; it will not only make your organization more efficient but at the end of the day more profitable.

One of the easiest benefits to derive from a CCoE is to use it to bring in top compliance talent, leadership talent and others to put on regular “Lunch-n-Learn” sessions for your compliance team and any others you want to include. It could be as straight-forward as a combination of deep dives into a compliance nuts and bolts topic and current event updates. You could bring in a wide variety of speakers and the topics would only be limited to your imagination. You could also use it to set a 12-month agenda so as to establish an assigned set of topics.

Using this same format, I could work with you and each team member to set up a personalized training/coaching program to help them fine tune their own compliance expertise. While I can provide leadership training, it would not be designed to focused on leadership development but on compliance development. It would include meeting with team members around specific professional learning with me curating a set of materials for them. The materials would be both downloadable audio and written materials. The offering also provides up to 5 hours of phone consulting  per month for any issue they may want to discuss.

Finally, how about a podcast series to further communicate compliance within your organization? Each podcast offering is a 5-part series, constitute one story arc and are each is  about 5 minutes in length. The podcast series can be a variety of interviews led by myself, commentary by your compliance team or business and myself. While there would be a fully integrated story line, each podcast and accompanying text is a stand-alone communication piece that could be used for a compliance communication. A series such as this will allow you to not only communicate a compliance message more effectively but reach a much larger audience than in any other format; live, audio video or in-person. Yet there are two other reasons why you should engage this service, it would enable you to relate a detailed compliance communication about your organization, its vision and its people.

Over this past week, I have listed several different types of services offerings to help you move your compliance program forward and as you can see from these exemplar offerings, I can provide you with many different, customized and unique services to help you achieve that goal.

CONVERGE19 is in its 4th year of bringing together the world’s leading companies for 2 days of dynamic speakers, thought-provoking breakout sessions, and opportunities to connect with like-minded professionals. You will leave the conference with new resources and best practices allowing you to continue the hard work of driving ethics to the center of your business. In today’s episode I visit with Nicole Pitts, founder of the Ethintegrity about her talk at Converge19, on Effectively Increasing Employee Engagement from ’Shop Floor’ to ’Top Floor’ through Play.

Struggling with employee engagement? In this session, you will learn how to effectively increase employee participation and facilitate discussions on complex ethics topics across cultures and educational levels. This will lead to a better understanding of the compliance program as well as identification & mitigation of risks from all levels of the organization. Explore the benefits of using the LEGO® SERIOUS PLAY® methodology to promote fruitful discussions to help the individual and the organization embed integrity into daily activities.

For more information on Converge19, click here.

For more information on the Ethintegrity, click here.