Compliance and Ethics: Ideas & Answers. Edition 33

Dear friends,

Welcome to the 33rd edition of Compliance and Ethics: Ideas & Answers!

Today, we start by looking at ethical habits of mind. What are they, how can you benefit from them and what to watch out for. Jeff Kaplan has come great insights on the topic. Then we have a nice piece from Adam Balfour on how bribery is not just a foreign problem.

And as always, there's more content on our website so please do?visit us there?to read our other articles.

Thank you, Joe.

Ethical habits of mind

by Jeff Kaplan

Long ago I began to worry that my daughter – then eight-years old – was insufficiently attentive to safety risks when crossing the street. I proposed that she keep a “safety journal” so that these issues would be top of mind. She declined (although she did promise to be more careful in crossing the road).

Still, this (and other) experiences have led me to ask: what are the ways in which habits of mind promote compliance and ethics (C&E) and which have the opposite effect?

At the outset I note that an ethical habit focus does not envision a whole new way of “doing C&E.” Rather, it is merely an aspect of risk assessment.

Moreover, this inquiry will be largely irrelevant to risk assessment at many organizations (including families with eight-year old kids). ?But in those contexts where it is relevant it can be very useful.

For example:

• Engineering firm employees often deal with workplace processes to a considerable degree. I believe – from my experience developing, improving and assessing engineering firms’ C&E programs – that this enhances the appreciation of processes generally, which can be very helpful in meeting C&E needs.
• In various industries, such as energy, employees embrace a “safety culture” that promotes risk areas beyond traditional safety compliance. This can be a powerful positive force for promoting C&E.
• In various financial service firms core day-to-day commercial behavior – such as bluffing – weakens the traditional ethical fiber of many companies. History has shown this to be a very powerful anti-C&E force.

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Keep reading this article on our website

Bribery Is Not Just A “Foreign” Problem

by Adam Balfour

Bribery is often discussed in the context of the far reaching U.S. Foreign Corrupt Practices Act (or FCPA for short) - while bribery is more prevalent in some countries than others, no country is free from the problem. The allegations and charges this past week relating to a U.S. Senator (as well as other people) highlight that corruption exists everywhere, including here within the United States.

The charges also highlight the many forms that bribery can take, including (as highlighted in the DOJ press release) “gold, cash, a luxury convertible, payments toward… [someone’s] home mortgage, compensation for a low-or-no-show job…, home furnishings, and other things of value.”

While the U.S. is generally a lower risk country for bribery, it is by no means risk free (and ranked as the 24th country on the 2022 Corruption Perceptions Index). Corruption exists everywhere and the efforts to combat corruption (and the devastating impacts it can have on people) must exist everywhere too.

I hope you found today's journal valuable and, if you would like more analysis and insight?please visit and bookmark our website.