i-Sight Investigation Blog Weekly Review

September 10, 2010   |   Tags: , , , ,  

BP released two pretty big reports throughout the past week. On the i-Sight blog this week, we discuss the reports from BP, as well as how to develop standout ethics and compliance policies. We also announce our attendance at a number of health care fraud conferences with Thomson Reuters. Enjoy!

Tuesday:

“You’ve heard it before- a strong ethics and compliance program begins with a top notch workplace ethics and compliance policy. But do any of these sources ever tell you exactly what makes an ethics and compliance policy “top notch”? Most of the time, the answer is no, which is why I have decided to dedicate this post to helping you better understand the elements of a top notch ethics and compliance program. It’s important to understand that each company’s ethics and compliance policy will be different, as policies are built around a company’s processes and is influenced by the industry in which it operates. However, there are common elements that must be included in every company’s ethics and compliance policy- it’s the “little extras” that are included that separate the top notch ethics and compliance policies from the not-so-stellar ones.”

Wednesday:

“The Deep Water Horizon explosion and the massive oil spill into the Gulf of Mexico, made it clear that BP- and the rest of the oil industry, have a lot to learn. Almost six months after the spill, BP has issued a report for the U.S. Bureau of Ocean Energy Management, Regulation and Enforcement. The report is titled “Deepwater Horizon Containment and Response: Capabilities and Lessons Learned,” and describes what went down during the Deep Horizon incident and what is being done to ensure an event like that doesn’t happen again. This morning, BP released another report. The new report is based on findings from the internal investigation at BP that was launched to determine the causes of the explosion and spill.”

Thursday:

“The signing of the Universal Health Care Bill in the US brought to light the need for solutions to detect and prevent health care fraud. Payment recapture initiatives were revamped earlier this year throughout the US and are predicted to put at least $2 billion over the next three years back into taxpayer pockets. As controls surrounding health care fraud detection and prevention are tightened, it’s likely that there will be a rise in the number of health care fraud related investigations. Employers, medical professionals, insurance companies and all other parties in the health care industry need to be prepared to handle increasing case loads.”

i-Sight Investigation Blog: Weekly Review

September 3, 2010   |   Tags: , , , , , , , , ,  

This week, HP agreed to a $55 million settlement with the US Department of Justice, ending the month of August in the news- the same place the company found itself in at the start of the month. Some of our other posts this week focused on information to include in investigation reports and how your company’s CIO and CSO can be used as key players in ethics and compliance. Here’s a review of our posts from this week:

Monday:

“Is this what you look like when it comes to preparing investigation reports? Writing investigation reports doesn’t have to be daunting. A standardized reporting structure improves the consistency of reports amongst investigators. Standardized reporting provides investigators with a reporting format to follow and reduces the time spent preparing investigation reports. This information is all fine and dandy, however, a question we frequently receive is, what information do I actually need to put in an investigation report?”

Tuesday:

“A company’s ability to effectively use technology to monitor, share and manage information contributes to the success of its ethics and compliance program. Some laws and corporate policies contain compliance requirements that can only be executed by a company’s IT department. In my opinion, a company’s Chief Information Officer (CIO) and/or Chief Security Officer (CSO) is equally as important as the Chief Ethics and Compliance Officer (CECO) when it comes to maintaining workplace ethics and compliance. Since CIOs are responsible for implementing IT systems and controlling the flow of information into and out of a company, CIOs help protect their company from data breaches and other technical risks. As ethics and compliance grows as an IT concern, an increasing number of companies have reported looking for CIOs, CSOs and other IT staff that not only possess the required technical skills, but also have personal values and morals that are similar to those of the company.”

Wednesday:

“So long sweet summer. However, for the folks at HP, the past month has been anything but sweet. In early August, HP announced the resignation of Mark Hurd following an internal investigation into sexual harassment allegations made against the now former CEO. As August ends, HP is making headlines again- this time following an investigation into alleged kickbacks paid by the company. HP agreed to a $55 million settlement, as the company was accused of paying kickbacks to the US government in exchange for business contracts. Here’s a look at the past month at HP, as well as some lessons the company should consider applying when rebuilding its corporate ethics.”

Thursday:

“September is shaping up to be a busy month for us at Customer Expressions, as we announce today that we will be exhibiting the i-Sight Compliance and Ethics Investigation Software at the 18th annual Business Ethics and Compliance Conference. The conference is hosted by the Ethics & Compliance Officer Association and this year it’s being held in Anaheim, California from September 21-24th. We attended this conference last year when it was held in Chicago and are glad to be returning again this year.”

i-Sight Investigations Blog: Week in Review

August 27, 2010   |   Tags: , , , , , , , , , , , , , ,  

This week we focused on the tactics Xerox used to rebuild its corporate impage after the 2002 accounting scandal charges. Other topics discussed this week include investigating sexual harassment allegations in the workplace and measures companies can use to protect the personal information of employees and clients. Here’s a review of our posts from this week:

Monday:

“The turn of the century was marked with a number of accounting and ethics scandals that would significantly alter the importance of corporate ethics and compliance. The Securities and Exchange Commission (SEC) began investigating the accounting practices at Xerox in 2000, which eventually led to Xerox agreeing to pay a $10 million settlement. During Xerox’s post-scandal transformation, Sarbanes-Oxley came into effect to improve financial and accounting compliance. Today, Xerox has turned their practices around and secured a spot on numerous ethical company lists. This post discusses the tactics deployed at Xerox to regain consumer confidence and instill ethics and compliance back into the company.”

Tuesday:

“We, Customer Expressions, will be sending a team down to Chicago to attend the  Annual Compliance & Ethics Institute, hosted by the Society of Corporate Compliance and Ethics. The conference runs from September 12-15 and features presentations from chief compliance and ethics officers, CEOs, certified compliance and ethics professionals, lawyers, compliance analysts and many other professionals in the field of ethics, compliance and risk management. While we are away, we will be blogging from the event and interviewing industry professionals.”

Wednesday:

“Sexual harassment occurs all too frequently in the workplace. Many recent sexual harassment allegations that have been made have been directed at top level executives. As investigators, you understand the value of maintaining compliance, confidentiality and promptness when investigating incidents of sexual harassment. Regardless of the employee’s level in the organization, each investigation must be handled with objectivity, follow company policies and reprimand those found guilty of policy violations. Previously, we blogged about a number of sexual harassment related topics, including developing anti-sexual harassment policies, tips for preventing and detecting sexual harassment, as well as the different forms of sexual harassment against males and females in the workplace. This post will focus on addressing sexual harassment complaints and investigations into sexual harassment allegations, to ensure company policies are enforced and violators face appropriate consequences.”

Thursday:

“The issue of personal information protection is a hot topic. Companies such as Google and Facebook have been questioned in regards to their privacy policies, as the personal information gathered from users has been leaked to the public on multiple occasions. Most recently, the University Health Network made headlines when patient information was leaked due to the theft of an unprotected USB key- we discussed the topic in the post “Maintaining Information Security and Privacy.” Sharing information has been made easier due to the Internet and electronic files, which raise concerns when it comes to regaining control over personal information protection. As technology advances, the risks surrounding information privacy continue to increase. Will your organization be ready to respond to tighter information controls?”

i-Sight Investigations Blog: Week in Review

August 20, 2010   |   Tags: , , , , , , , , , , , , ,  

This week we continued to look at the lessons learned from the HP CEO ousting, as well as the dramatic exit of JetBlue employee Steven Slater. Focusing on key topics such as tips for detecting harassment and discrimination in the workplace and employee theft investigations, here’s a review of our posts from this week:

Monday:

“Many of us rarely think about where products come from or how they arrived at their destination safely. Much of what we use and consume on a daily basis goes through many steps and precautions along the way through a company’s supply chain.  Civacon is the world’s leading provider of cargo tank components and systems designed for safe, profitable handling and transportation of hazardous bulk products. Civacon’s vents, valves and other equipment help safeguard against petroleum, liquid and chemical spills and get dry bulk commodities to their destinations. In order to effectively manage complaints and quality issues, Civacon implemented the i-Sight Quality and Correction Action Software.”

Tuesday:

“For some, the work environment can be an unwelcome place. Employees who fall victim to workplace discrimination or harassment react differently- some confront the issue by discussing it with their manager, while others, in the case of last weeks feed up JetBlue employee, grab a beer, release the emergency exit and slide on out in a dramatic exit. Employees don’t always feel comfortable bringing harassment and discrimination incidents forward, as fear of retaliation and being singled out by fellow employees adds additional stress to the employee. In some workplaces, the culture and tone from management may also hinder an employee’s willingness to come forward. In many jurisdictions, employers are legally responsible for providing employees with a safe, harassment and discrimination free workplace. Employers need to know how to monitor and recognize signs of harassment and discrimination in the workplace. Recognizing the signs and symptoms of distressed employees helps to identify workplace issues and draws attention back to sections of the company code of conduct that may need to be reinforced or require additional training.”

Wednesday:

“According to a report from the Association of Certified Fraud Examiners, occupational fraud and abuse costs businesses in the United States upwards of $400 billion a year. Today’s business leaders must focus on protecting their brands through prevention and proactive measures to rid their workplace of fraud, theft, violence and other unethical acts. However, managers still need to be prepared to react to these types of events and conduct investigations into reported allegations, as accidents do happen. One of the main concerns facing businesses during times of economic recession is employee theft. As businesses do their best to cut unnecessary costs, they must also monitor for theft, as the costs associated with theft place significant burdens on the organization. We have covered tips for preventing and detecting employee theft in our posts “Workplace Theft & Fraud Prevention Tips Part 1,” and “Workplace Theft & Fraud Prevention Tips Part 2,” therefore, this post will focus on the proper handling of workplace theft allegations and conducting employee theft investigations.”

Thursday:

“There have been countless articles written since August 6th, when HP ousted their now former CEO, Mark Hurd. In particular, this article from the Wall Street Journal focuses on the importance of proper expense reporting and how the HP example has already served as a lesson in numerous workplaces. The article features comments from ERC President, Patricia Harned, in which she states:

“Companies will often use very public cases as a teachable moment to remind employees why certain policies are so important.”

The article discusses the increased harshness faced by executives who make poor, unethical decisions, as they are supposed to be leaders and set an example for their employees. The article also features a great discussion about the importance of administrative staff in detecting inaccurate or unjust expenses.

i-Sight Investigations Blog: Week in Review

August 13, 2010   |   Tags: , , , , , , , , , , , , , , , , , ,  

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

“Early last week, a USB key containing hundreds of Ontario patient health information files was stolen. According to the CBC, the USB wasn’t encrypted and was stolen from the purse of a University Hospital Network (UHN) employee. The theft of these files has resulted in a call for efforts to increase the security of sensitive information. This is the second instance in under a year where private patient information was compromised in Ontario due to theft. The lesson learned from this story can be applied to any business that maintains client or customer personal information records: make sure sensitive information is encrypted. Controlling access to information can further prevent information security breaches, as the number of people viewing sensitive information is decreased. Regular evaluation of training programs and internal procedures related to information security must be undertaken to ensure each employee is completing the necessary steps to safeguard information. ”

Tuesday:

“On Friday, HP CEO Mark Hurd was asked by the company’s board of directors to submit his resignation. As reported in the TechCrunch Article “HP CEO Mark Hurd Resigns, This Looks Messy,” the outcome of an investigation into sexual harassment allegations against Hurd “concluded that there was no sexual harassment violation, however it did find that Hurd violated HP’s ‘Standards of Business Conduct.‘” When news broke about his departure, Hurd claimed he himself hadn’t lived up to his own standards regarding integrity and respect. Therefore, if he wasn’t able to live up to these standards himself, what message does that send to the rest of the employees at HP?”

Wednesday:

“Employers must be prepared to follow new legislation that has been enacted to increase protections for whistleblowers. The recent passing of the Dodd-Frank Act continues to follow the trend towards putting an end to whistleblower retaliation- as well as rewarding whistleblowers for bringing forward evidence of unethical or criminal acts taking place within an organization. Whistleblowers can become victims of retaliation whether it comes from managers or fellow employees.”

Thursday:

“As part of the National Business Ethics Survey conducted by the Ethics Resource Centre (ERC), the ERC releases supplemental research briefs that focus on a number of topics from the survey in a more detailed manner. The most recent release featured information pertaining to the cost of retaliation on both the company and its employees. As mentioned in yesterday’s post about the Dodd-Frank Act and its whistleblower protections, retaliation is a growing concern in the workplace. In many organizations, employees are an employer’s eyes and ears when it comes to catching workplace misconduct. To establish a workplace that is safe and enjoyable for all, employers must work to create an environment that encourages the reporting of misconduct. The ERC survey concluded that companies with a zero tolerance policy for retaliation experienced very few instances of retaliation, which demonstrates that efforts to prevent retaliation do have an impact.”

i-Sight Investigations Blog: Week in Review

August 6, 2010   |   Tags: , , , , , , , , , , ,  

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Tuesday:

“As with any human relationship, once the trust is gone, the relationship usually goes with it. Last week, Deloitte released the findings of their annual Ethics & Workplace Survey. The focus of the survey this year was on trust in the workplace. Deloitte began publishing their annual Ethics & Workplace Survey back in 2007.  The points of concern identified in the survey provide business leaders with insight into growing issues that must be addressed in order to retain valuable employees. The ethics and trust gaps identified in the survey bring to light the different views employees and employers have in regards to these two areas. After reviewing the results and methodology of the 2010 Ethics & Workplace Survey, I have put together some advice for rebuilding ethics and trust within the workplace.”

Wednesday:

“For the past 88 years, the Ethics Resource Centre (ERC) has been a source of information and guidance for ethics and compliance professionals everywhere. The information provided by the ERC serves as a benchmark for companies when gauging the success of their own ethics and compliance programs. The ERC conducts both national and private, single organization surveys, and publishes the results to help businesses and government agencies understand trends, gaps and best practices in ethics and compliance.”

Thursday:

“Workplace investigations vary between industry sector and must be tailored to the incident under investigation. In the financial services industry, there is an increased number of risks companies face, especially during tough economic times. Fraud, money laundering and compliance issues are only a few basic examples of financial crimes that require timely, thorough investigations. Financial crimes not only impact the reputation and sustainability of companies, but these crimes also have severe social impacts that change the lives of investors and the public at large. For example, the Madoff ponzi scheme left hundreds of thousands of people without their entire life savings, and for some, bankruptcy.”

i-Sight Investigations Blog: Week in Review

July 30, 2010   |   Tags: , , , , , , , , , , , , ,  

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

“There’s no point investing in and implementing an ethics and compliance program unless the time is spent integrating the program into every aspect of an organization. The need for companies to develop effective ethics and compliance programs has been acknowledged by several government agencies- examples are the SEC in the US and the government in the United Kingdom. Both groups have recently passed legislation or made amendments to existing guidelines, focusing heavily on the importance of ethics and compliance at all levels of an organization- especially at the top. Employees at each level contribute to the success of a company’s ethics and compliance program. Integrating ethics and compliance at each level helps ensure the message from the top makes it all the way down to the lower levels of the organization. Training, messages and other ethics and compliance initiatives must be developed to evolve with employees as they move through the company. That being said, employees at various levels need to be prepared to address different ethical issues they may encounter based on the role they play in the organization.”

Tuesday:

“The values associated with workplace fraud continue to rise- especially during economic downturns. Preventing workplace fraud begins on the inside of an organization. One of the largest fraud risks companies must address is the opportunity for fraud to occur. There are a number of anti-fraud techniques and systems that are easy to implement within any organization. When fraud grows out of control within an organization, reputations and public trust are destroyed. To reduce the opportunity for fraud to occur, accounting and money handling responsibilities must be divided. Monitoring and enforcement of anti-fraud programs is necessary in order for the program to be effective and for employees to take it seriously. When employees know they are being watched, their work is being reviewed on a consistent basis and punishments are administered to those who violate anti-fraud policies, there’s less room for fraud to go undetected.”

Wednesday:

“The $1.6 billion fine handed down to Siemens in 2008 was much more than a record breaking fine, it was a lesson for other companies to learn from. Prior to the bribery scandal, Siemens had an ethics and compliance program in place, however, there was a missing link between leadership and the enforcement of the program. The company’s cooperation during the SEC investigation lead to a reduced penalty, but also gave way to a complete re-design of the company’s internal ethics and compliance controls. There are many lessons learned from the Siemens charges, the reaction to the investigation and the actions taken by Siemens to position the company as an ethics and compliance leader in the post-scandal era.”

Thursday:

“In order for a workplace investigation to be credible, investigators must deploy certain tactics to verify the accuracy of interview responses. In a previous post, Investigation Interview Questions to Determine Credibility, we reviewed the EEOC’s 5 factors to consider when determining statement credibility during investigation interviews. One of the toughest challenges to overcome during investigation interviews is the fact that witnesses may withhold or modify their responses to protect the subject- or the complainant and possibly even themselves. As investigators are often pressed for time when conducting internal investigations, they cannot afford to get hung up on determining who is correct in the “my story vs. their story” battle. We have compiled a list of simple tips and techniques investigators can use to determine investigation interview credibility.”

i-Sight Investigations Blog: Week in Review

July 23, 2010   |   Tags: , , , , , , , , , , , ,  

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

“For many organizations, situations involving workplace bullying remain a growing concern. Whether the situation involves peers or superiors, all matters involving physical or mental bullying must be investigated promptly, with appropriate punishment administered. Like many forms of workplace harassment or discrimination, movements are being made to hold employers responsible for protecting employees from workplace bullying. In May, the Wall Street Journal published an article that discussed the signing of a bipartisan measure in the state of New York that would allow employees who have been abused in any form within the workplace, to place charges against their employer in a civil court. Following in the footsteps of the UK Bribery Act and US FCPA, the anti-bullying legislation proposed in New York states that employers may not be held liable in a workplace bullying case if they can provide sufficient evidence that a program is in place to prevent such incidents from occurring. ”

Tuesday:

“IBM is committed to developing solutions to improve the transfer of information and providing businesses with solutions to simplify their business processes. In 2004, IBM became one of the founding members of the Electronic Industry Citizenship Coalition (EICC). IBM abides by- and helped to develop, the framework established by the EICC as guidance for their supply chain social responsibility program. In one of our previous posts, “The Importance of Supply Chain Ethics and Compliance,” I wrote about the importance of an ethical supply chain. As product parts are manufactured all over the world, it’s important that companies take responsibility to ensure all members of their supply chain act in a socially responsible manner. Companies are encouraged to review and implement their ethics, compliance and social responsibility policies within companies involved in the supply chain.”

Wednesday:

“i-Sight Investigation Software is a customizable, centralized case management solution developed to help investigators, HR personnel and other members of a company’s investigative unit effectively manage case files. The above video provides a verbal and visual overview of how i-Sight Software works and the benefits it has to offer. Here are some of the topics discussed in the short video.”

Thursday:

“The Global Reporting Initiative is comprised of a very large group of experts who collaborate on the development of global standards for sustainability reporting. Joining the GRI is voluntary. With transparency and sustainability emerging as growing trends in the late 1990’s, the GRI was created to provide companies with a standardized sustainability reporting framework. Dissatisfied with the level of transparency in corporate reporting, the GRI works to make sustainability reporting mandatory, as opposed to voluntary. In a previous post, “Social Responsibility Reporting Best Practices: Allstate,” I discussed the application of the GRI reporting techniques at Allstate. The economic downturn has forced businesses and their leaders to make changes to their internal controls and business processes by adopting sustainable solutions.”

i-Sight Investigations Blog: Week in Review

July 16, 2010   |   Tags: , , , , , , , , , , , , , , ,  

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

“Allstate uses their social responsibility report to tell the story of the company’s longstanding history serving the communities in which they operate. Allstate has been recognized as an industry leader, a great place to work and as a good corporate citizen. To communicate their message to the public, Allstate voluntarily uses metrics outlined by the Global Reporting Initiative (GRI). The GRI reporting method provides companies, including Allstate, with the necessary tools to increase transparency and report on sustainability initiatives.”

Tuesday:

“Although creating an ethical culture spans much further than workplace policies and procedures, it’s important for employers to set the tone for workplace ethics within these documents. Ethics and compliance programs help to establish a more secure workplace. An organization committed to ethics and compliance can reduce their exposure to risks, such as fraud and bribery, if employees are aware of the enforcement and consequences they will face if they get caught. Typically, if an employee knows they are likely to be caught or the penalty for violating regulations is significant, employees will be less likely to make risky decisions. With an increasing number of sentences and dollar values of fines handed out to both individuals and corporations for violating laws, enforcement agencies have demonstrated the need for ethics to provide security in the workplace.”

Wednesday:

“Almost two weeks ago, I was reading through a local paper, and stumbled across an article discussing the arrest of Nazir Karigar, a Canadian citizen accused of bribing an Indian official. Since our company is located in Canada, the article prompted me to dig a bit deeper and look into the implications faced by those charged under the Canadian Corruption of Foreign Public Officials Act (CFPOA). According to CBC News, it’s been reported that this is only the second time a charge has been made under the CFPOA. Canada is part of the OECD, which enacted the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions on February 15th, 1999. Canada has identified the need to work harder to crack down on the bribery of foreign public officials. As mentioned in the Wrageblog post “Questioning Canada’s Commitment to Combating the Corruption of Foreign Public Officials: Watching Bill C-31,” the country was labeled as a “laggard” by the OECD in 2009 for their lack in action when it comes to enforcing anti-corruption laws.”

Thursday:

“In order for an organization to implement a successful ethics and compliance program, they must take into consideration the existing flow of communication within the workplace. Communication isn’t something that should only be done during times of organizational change. To reduce confusion and improve organizational performance, employees require consistent, ongoing communication. Select communication methods appropriate for specific work environments and conduct regular communications audits. Asking for feedback identifies problem areas where messages are misunderstood or not received at all. Effective communication is necessary for both internal and external audiences. This post will focus on improving internal communication amongst departments, management and employees.”

i-Sight Investigations Blog: Week in Review

July 9, 2010   |   Tags: , , , , , , , , , , , , ,  

It seems to be that each week is busier than the last. Here are some of the things we blogged about this week- as well as some other pieces that caught our attention regarding internal investigation, human resources and ethics:

Monday:

“The efforts of employees at all levels of an organization contribute to the success of workplace diversity training. Everyone is diverse, whether it’s based on skill set, skin colour, religion, experiences- we are all different from one another in some way. Unfortunately, in some workplaces, stereotypes continue to hold precedence over the positive value diversity adds to a workplace. In order to reduce, and hopefully eliminate discriminatory actions from the workplace, effective diversity training is required. Train employees to respect the differences of not only their fellow employees, but the customers and clients they serve. Diversity training is becoming a focal point for many companies, as organizational leaders strive to create a workforce reflective of the communities they operate in.”

Tuesday:

“I frequently come across a number of articles related to the corporate culture at Zappos. After being acquired by Amazon, the online shoe and clothing retailer continues to maintain the values and culture that have been with the company since the beginning. New hires at Zappos receive 5 weeks of training in the areas of culture, core values, customer service and the company warehouse. The focus on culture is integrated into all departments, employee roles, performance reviews, mission, vision and goals at Zappos.”

Wednesday:

“Ottawa, Canada – July 6, 2010 - Customer Expressions Corp (CEC) announced today that it has partnered with Resolution Software of Ireland to expand the offering of i-Sight Software. The partnership provides CEC with a local presence to better service European prospects and customers. Resolution Software currently provides clients with solutions to support customer interactions and specializes in helping organizations improve processes for managing customer complaints.”

Thursday:

“Every organization faces a variety of factors that put their company at risk. Risks may vary between industries, however, one thing remains the same- employers are responsible for protecting their employees and providing them with a safe workplace by mitigating these risks. In some cases, accidents still happen, employees choose not to follow proper procedures and misconduct ensues. In these types of situations, companies will want to ensure they have an effective reporting system in place, as well as proper tools for conducting top notch internal investigations.”

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