1/6/15: Insider trading isn’t reserved for traders. In late December, the SEC charged two individuals in Chile with insider trading on nonpublic information that one person had learned while serving on the Board of Directors of CFR Pharmaceuticals S.A. Specifically, Juan Cruz Bilbao Hormaeche “… exploited highly confidential information from a...
Compliance Communications Blog
1/6/15: Insider trading isn’t reserved for traders. In late December, the SEC charged two individuals in Chile with insider trading on nonpublic information that one person had learned while serving on the Board of Directors of CFR Pharmaceuticals S.A. Specifically, Juan Cruz Bilbao Hormaeche “… exploited highly confidential information from a...
1/6/15: When you’re planning out 2015’s compliance goals, activities, and projects, it’s probably a good idea to look back at what happened in 2014. Matteson Ellis gives a helping hand with an article featured on Corporate Compliance Insights (reprinted with permission from Ellis’ FCPAmericas Blog). The article, “What FCPA Enforcement was Thinking...
1/6/15: Charles Dickens’ A Christmas Carol has a few things to teach compliance professionals that have nothing to do with Christmas or carols. The story and modern behavioral psychology both drill into a dilemma that also stands at the center of behavior change and compliance. How do we promote behavior change that results in...
Purists of a certain sort will argue (as purists are wont to do) that the ne plus ultra of adaptations of Charles Dickens’ A Christmas Carol is the 1951 film version starring Alastair Sim as Ebenezer Scrooge. I beg to differ, as my kids and I have been watching the Mr. Magoo version again lately, and I find that the sound of Jim Backus’ voice is deeply tied up in my psyche with the aesthetic of the holiday season. Plus there are some really wonderful songs in that cartoon! (“Ringle, ringle, coins when they mingle make such a lovely sound…”)
But no matter! Whatever version compels you, compliance and ethics professionals should take careful note of this tale. Why? Because corporate compliance and ethics is fundamentally about changing behavior. (Of course it is also very much about tracking, testing systems that track, and investigating behavior, but in the first instance it is about exerting an influence on employees’ behavior.) And this is one story, albeit a fictional one, which illustrates just how powerful
12/16/14: OtisMed Corp. and its CEO Charlie Chi didn’t do the medical device industry, his patients, or his firm’s eventual parent company any favors by taking a twisted path to selling the OtisKnee orthopedic cutting guide. The guides were designed for use in knee replacement surgery but their application for marketing clearance was...