Fcpa Compliance Report

Under the Evaluation of Corporate Compliance Programs, Prong 2, it states: Senior and Middle Management Conduct at the Top – How have senior leaders, through their words and actions, encouraged or discouraged the type of misconduct in question? What concrete actions have they taken to demonstrate leadership in the company’s compliance and remediation efforts? How does the company monitor its senior leadership’s behavior? How has senior leadership modelled proper behavior to subordinates? This requirement is more than simply the ubiquitous ‘tone-at-the-top’ as here the Justice Department wants to see a company’s senior leadership actually doing compliance. How can senior management operationalize compliance going forward? One of the best places to start is the article from the Harvard Business Review by Professor Lynn Paine entitled, “Managing for Organizational Integrity”. Larry Thompson, former PepsiCo Senior Vice President of Governmental Affairs, General Counsel and Secretary, discussed the work of Profe