Blog

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…)

(more…)

(more…)

(As first published in the Stanford Social Innovation Review on November 16, 2012) The New England Compounding Center meningitis case spotlights the tragic consequences of failed organizational ethics. The news is rife with stories of natural disasters (the tsunami, Haiti, Hurricane Sandy) and human tragedy (cancer, poverty). These problems are beyond our control despite best practices and best efforts. The news is also rife with silence. Silent rapes in India, decades of hidden abuse by knighted BBC star Jimmy Savile, and the surreptitious collection of user data by the ubiquitous Angry Birds app all demonstrate this. But the 32 deaths from meningitis...