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Perfection is not possible … imperfection is not an excuse The recently updated guidelines to the United States Foreign Corrupt Practices entitled A Resource Guide to the U.S. Foreign Corrupt Practices Act (November 2012) offers myriad helpful principles, case studies, and clarifications to facilitate compliance and proactive engagement with the authorities on various issues potentially covered by the FCPA. However, perhaps the most useful and reassuring guiding principle appears late in the document in Chapter 5 “Guiding Principles of Enforcement”: neither the Securities and Exchange Commission (SEC) nor the Department of Justice (DOJ) seek perfection. Nor should you. (more…)

Recent press reminds us that in addition to systemic unethical behavior (African dictators siphoning oil revenue or tax evasion networks), more specific pressure points create enormous and contagious ethical challenges. Whether reporting quarterly revenue at 11:59 pm on the last day of the expecting a signed contract the next morning, a weakness in processing bank transfers involving Iran, or failure to react vigorously to governmental threats to withdraw business privileges unless a Swiss bank account balance rises, pressure points should be a key element of ethics oversight for every board and senior management team. (more…)

I have been obsessed with time as an intellectual matter (Proust and Einstein…), a cultural matter (orchestra conductors, Big Ben, the Great Wall building process), an organizational matter (school bells, oven timers, day light savings time, airport schedule boards, time zones…), and a social matter (fashionably but annoyingly late). Time is perhaps the biggest challenge of ethics oversight for all organizations, whether for-profit, non-profit, academic, or governmental. The ethics of time is indeed intellectual, cultural, organizational, and societal for most organizations. Above all time also underlies the challenge of managing unpredictability that underlies all of my ethics work. The key...

I just finished Harvard professor Stephen Greenblatt’s fascinating and thoroughly enjoyable The Swerve [1]. Professor Greenblatt guides us through the wanderings of the main character, book hunter Poggio Barcciolini, who finds the lost manuscript of  Lucretius’ poem “On the Nature of the Universe” that was to influence the start of the Renaissance and scientific and humanistic thought for centuries thereafter. The book’s key underlying theme, the unexpected collisions of tiny particles as a foundation for the universe, leads this blog to ask how events and people engaged in business, the non-profit sector, or academia (organizational atoms) handle unexpected collisions. In...

I recently reread renowned Stanford University Professor Philip Zimabardo’s brilliant essay “The Psychology of Power”. [1] Using examples from Abu Ghraib to his own famous prison experiments, Professor Zimbardo reminds us that we “are all subject to…underemphasizing situational explanations” while overemphasizing “individual orientations”.[2] (more…)