Gifts and hospitality policies shall be included in any compliance program, that is undoubtedly true, that said, particularly for hospitality, some may be tempted to consider accepting an extra trip, a first class and or a suite upgrade as a minor issue. This is unacceptable. Bottom line. One of the few things one may be certain … Continue reading Hospitality and blackmailing; two sides of the same coin
A year after my first piece, I am guest writing again for the Ethical Boardroom, this time about the anti-bribery standard ISO 37001 and its pitfalls. You can read it here
Whistleblowers around the world still fear retaliation, it is not surprisingly, therefore, that most of them decide to stay anonymous. However, is omitting his own name enough? Probably not, at least for reports made via phone calls. Even without disclosing his name, anyone, while talking on the phone, may release a number of details which … Continue reading GDPR: How to anonymise or pseudonymise whistleblowers allegations
The GDPR is almost here, May is not far, therefore, organisations are increasingly worrying about being compliant with the data protection Regulation. One of the main topics is the DPO selection. Should I hire one? What exactly qualifies to be a DPO? Should a DPO be a lawyer? These are just some of the most … Continue reading GDPR Why your Data Protection Officer should be a Lawyer
I recently came across this post where prof. Michael Johnston defined relying on political will ‘magic thinking’ (actually he extended the same reasoning to the civil society). Given my experience in high risk countries, I respectfully disagree with prof. Johnston. Whilst corruption is strictly connected to the human kind (it can happen everywhere and in … Continue reading Is Political Will Necessary to Fight Corruption? Yes!
A few months ago, the American DoJ issued its Evaluation of Corporate Compliance Programs. The French Anti-Corruption Authority did the same very recently (here the link). What I immediately noticed reading the two documents is that the ‘new’ ISO 37001 is not even mentioned…
It’s that time of the year again; many business meetings, several deals to close before the end of the year, dinners and…season gifts. What can be assumed to be an innocent gift can, in reality, be a violation of anti-corruption laws, turning a festive moment into a nightmare. Let’s see what we can do to … Continue reading Christmas time, review your gift policy