A new web site for your Working for Integrity news and information

There is now an official website for Joe Murphy and Building a Career in Compliance and Ethics. You can visit it here.

Expect a banner link to the site to appear prominently on this blog later today (replacing two other banner links above all posts). The link will also be added to the 'Working for Integrity Links' section in the sidebar.


In related news, this will be the final post on this blog. Joshua Leet, who has been the primary blogger, is now moving on to new work, having completed his role in the Working for Integrity project. This blog will be left as is for as long as Blogger leaves it, but with both books out and no immediate plans for further projects, the blog has served its purpose.

Please visit Joe's site for all your future Working for Integrity needs.

Thank you

Working for Integrity linked by another site

We've just heard from a site dealing in jobs and careers that they've chosen to link to our blog. Check them out at:

SearchJobsCareers.Com - International, Overseas & World Wide Jobs and Careers - International Jobs and Careers. Free employment site free corporate job site and career tools from Search Jobs Careers Recruiting corporate career site service, including free resume search, free job postings and free resume postings.

You'll also find a link to that site in a new link category in our sidebar: Sites that Link to this Blog

An Excerpt to Tide You Over - Risk Areas

Still don't have a copy of the book?
Here's another small excerpt, this time from a list included in the books.

From Chapter 1 of both books:

Potential Compliance Risk Areas
· Antitrust/competition law
· Conflicts of interest
· Consumer protection/advertising
· Document management/retention
· Employment discrimination/labor
· Environmental
· Government investigations/dealings
· Harassment
· International
· Money laundering
· Political contributions/bribery/lobbying
· Privacy
· Product/service safety
· Taxes
· Wages and hours/ fair labor standards act (flsa)
· Workplace safety and health


To see a larger list and read about how compliance programs address these risks--and how this relates to the need for compliance professionals--order your copy of Building a Career in Compliance and Ethics.

Article Alert - JobWeb

Today, more article news, as JobWeb has posted an article by Joshua Leet. The article is titled "Do I Have to Sacrifice my Values to Succeed in Business" and it offers advice and information about Compliance and Ethics to college students.

The article is currently accessible at the top of the Career Library page or by clicking here.



This article joins last week's at SmartPros in helping to promote the new book and the field.

Reminder: You Can Buy the Book Today

Well, it's March, and that means that Building a Career is now available for immediate order at both SCCE and Amazon!

Further, while it was discounted for pre-order at Amazon, it is now listed at its regular price of $29.95, so unless you're using an Amazon gift certificate, we suggest ordering directly from the publisher SCCE.

There should be a more extensive web page up for the book soon. We'll keep you updated on that.

Marshaling Integrity - Rodney Smith

These excerpts are taken from our interview of Rodney Smith, a former in-house environmental, health, safety and ethics analyst.

I would say a nice chunk of my time is done for training. I do business law and ethics training, though not comprehensively; I just get into a few of the topics, including Harassment Prevention, Foreign Corrupt Practices, Copyright Compliance, and Environmental Law. The majority of my educational emphasis is Environmental, Safety and Health, so occupational health, safety and environmental is what I specialize in. In addition to training, I do a lot of procedure writing, auditing. Those are my three primary roles: auditor, policy and trainer (to make sure they uphold the policies).

They definitely have to be open-minded. A huge mistake would be to be close-minded, not willing to change, because you are going to be challenged, constantly. If you come up with a solution or program you think will work, there are always going to be people that tell you it won’t. They’ll have good reasons why, and you need to be able to defend yourself without being close-minded. You have to be really open-minded to all possible alternatives. There are a lot of ways to approach any single problem, and a lot of solutions. You have to be extremely creative with some of the solutions when it comes to compliance. Especially when the law’s not entirely defined. It’s not always concise; it doesn’t tell you what to do. It just leaves it open-ended, sometimes. So in situations like that, the person has to be willing to work with other people, be a team player and be open-minded. Always open.

Rodney Smith's interview appears in both Working for Integrity and Building a Career in Compliance and Ethics.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Joseph Murphy

These excerpts are taken from our interview of Joseph Murphy, an in-house compliance lawyer and outside advisor (and Working for Integrity co-author).

In my role in CSLG I provide advice to companies. Much of this I can do from my office, on the phone or by e-mail. I may write or review draft company documents—codes, policy statements, audit reports—and provide the client with changes and ideas. I also do training and audits for companies. The training involves on-site visits and presentations to employees. These sessions are typically interactive, using exercises like role-plays or other techniques to involve the employees in the learning process. The audits also involve on-site visits including review of documents and interviews with employees, as well as walking the premises. I also participate in client meetings addressing a variety of compliance program elements.

Government needs to do more to recognize compliance programs and compliance professionals. For example, if you look at the Sarbanes-Oxley Act, you will not find any reference to compliance programs or compliance officers, even though this law deals with preventing corporate misconduct. This omission is a mistake. Government needs to make it clear that it will treat companies better if their compliance programs are rigorous and staffed by empowered compliance professionals. Government also needs to take steps to eliminate the legal barriers to having effective compliance programs. It should be clear, for example, that the results of compliance audits cannot be used against companies.

The people who are doing this work need to see themselves in a larger context as practicing in the field of ethics and compliance. They need their employers and society to recognize this as a discrete and very important field of practice, and that it is becoming truly a profession. It is necessary because the people doing this work need that degree of protection; they need that degree of independence and empowerment if they are going to work effectively.

Joseph Murphy's interview appears in both Working for Integrity and Building a Career in Compliance and Ethics.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)


(This entry - and most of the blog - was written by Joshua Leet)

Marshaling Integrity - Linda Lipps

These excerpts are taken from our interview of Linda Lipps, a compliance officer who worked her way up into the field.

I’ve been in the Ethics arena since 1996. I was in an HR role with a large privately-owned company in Houston, and one of the principal owners came to me and said, “Linda, we’re thinking about implementing a values-based ethics program, and I’d like for you to become involved and work with our general counsel on this.” At the time, even from an HR perspective, to hear the term “values-based ethics program” was pretty unfamiliar. I really was clueless about what he was talking about, but I started doing some research, and of course, came across the Federal Sentencing Guidelines, and spent many hours talking with our general counsel. I decided this was something that was really intriguing to me, that I would enjoy doing, and could still use my people skills.

I started working with our general counsel, as well as our vice president of human resources, and spent a year just researching, because in 1996, there wasn’t a whole lot out there. We joined the Ethics Officers Association; I remember the first EOA meeting I went to, we filled a large, private dining room in a hotel. Today, EOA has to search for a hotel property to host a conference in order to be able to accommodate everyone. Within the first year, I attended an executive course, co-hosted by Bentley College and EOA, near Boston called Managing Ethics in Organizations (MEO). So from research, the EOA, networking and an executive course, we started putting a program together: implementing a helpline, putting in a case management database, designing a code of conduct, and rolling out ethics training. I was with this company for five years.

If someone is out there, and wants to get involved in the world of ethics, the best way to do it is to try to get on with a company and start out handling some of the calls for case intake. That provides you a really broad feel and understanding of what the employees’ issues and concerns are.

Linda Lipps' interview appears in both Working for Integrity and Building a Career in Compliance and Ethics.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Odell Guyton

These excerpts are taken from our interview of Odell Guyton, a compliance officer for a large corporation.

The time I spend is really involved with a lot of senior executives at the company both in promoting and educating, making them and other employees aware of what compliance means and what we do as a group. We are also being partners with them. When I say partners, I mean that in a broader sense, in terms of assisting them in navigating through some of the complexities of this compliance area. We’re exposing them to how compliance touches their day-to-day work, and how we can be useful in making their work less risk-full, from a compliance-risk perspective, as well as providing guidance with regard to policies and company positions that they may not be exposed to on a regular basis, or have specific knowledge about.

There’s probably a larger, more visible opportunity now in multi-national corporations, in publicly traded corporations, primarily because of the impact of Sarbanes-Oxley. But then you have other laws that are coming into play at the state and local levels that are emphasizing compliance and emphasizing corporate ethics, company ethics, company compliance. You have things that are occurring in companies now that show a greater sensitivity/visibility to ethical conduct: not necessarily conduct that violates a legal standard, but conduct that violates ethical-sensitivity precepts.

I've never hired anyone just based on their degree; I hire people on the whole person. I’ve taken chances on people that haven’t had any formal training in compliance, because I knew that they had the ability and aptitude to understand (they would get the job done) over someone that had formal education in it. What can I say? I don’t think that having any particular piece of paper is going to make you more marketable; it depends on the individual job.

Odell Guyton's interview appears in both Working for Integrity and Building a Career in Compliance and Ethics.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Richard Gruner

These excerpts are taken from our interview of Richard Gruner, a law professor and author in compliance.

I do a substantial amount of research and teaching in this area, particularly in the context of Continuing Education programs and scholarly research articles that I write about the standards governing compliance, as well as some discussion of techniques relevant to compliance programs…I do teach courses on white-collar and corporate crime in which I discuss the impact of compliance programs and the developing standards governing compliance techniques.

I view the compliance field as a chance to be positive, really at two different levels. One is that I really do believe that effective compliance programs prevent offenses, and thereby serve the public and serve the interests of the corporation involved. So in that sense a compliance-oriented practice can be a very positive, constructive practice, more so maybe than a lot of legal, where you’re just trying to clean up somebody else’s problem. The other is that the setting of corporate liabilities is a setting where corporations can distinguish themselves in a positive way. They can show that they are indeed responsible and forward looking and publicly oriented by taking an aggressive, preventative stance. So in that sense it’s part of a corporate-level ethics that is very positive and which has gained increasing interest and concern in the last few years. So those aspects of both public service and particularly, corporate ethics and positive corporate action, are very positive sides of the compliance field.

Richard Gruner's interview appears in both Working for Integrity and Building a Career in Compliance and Ethics.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Peter Wymard

These excerpts are taken from our interview of Peter Wymard, who discussed the provision of online compliance training.

My role, specifically, is in our sales group. I spend my time out there in the world, quite frankly as best I can trying to get our message out. Now, if you think about it...what we do is provide a service over the Internet. Typically owners of a program are the legal departments of publicly traded or large companies that really have to care deeply about compliance & ethics issues, and the risk of compliance failure. So I am out there in the world, trying to get as close as I possibly can, to speak with the owner of the company’s compliance or ethics program. More and more frequently, companies have stand-alone compliance or ethics departments where there’s a clearly identified compliance officer or director of ethics.

Whatever you’re selling, it’s strategic selling, meaning they’re multiple buyers who weigh-in in the process: there’s the ultimate buyer, who’s going to sign the check; the ultimate owner of the program; perhaps user buyers, those people who on a daily basis may help administer the program internally; there’re the technical buyers, those folks who can’t say yes to a project, but they certainly can weigh-in heavily on saying no, that sort of thing. So whatever product you’re selling, it really requires significant buy-in from the prospective client from a number of forces. That’s making it a strategic sell.

Peter Wymard's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)


This is the final interview excerpt from Working for Integrity alone. Tomorrow, five excerpts from interviews that also appear in Building a Career in Compliance and Ethics will be posted.

Marshaling Integrity - George Wratney

These excerpts are taken from our interview of George Wratney, a former corporate ombudsman.

The function of the office rests on two pillars: one is neutrality; and one is confidentiality. The neutrality part is that we assure employees who call us or write us or otherwise contact us—knock on the door or trip us in the hall—that we don’t act as their agents, and we don’t act as agents for management. We’re a communications channel, and again I have to emphasize the word, alternate communications channel, for employees to raise issues in confidence.

Ombuds are not part of the management team of a company; they don’t investigate; they’re a conduit for information, back and forth, from the employee to the company, and then, when the results are determined, somehow the company, through the ombudsman, gets back [to the employee].

George Wratney's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Rebecca Walker

These excerpts are taken from our interview of Rebecca Walker, who we asked about providing compliance advice from a large law firm and also as a solo practitioner.

My interest in the beginning really lay in white-collar, criminal defense work. Compliance, especially then, in the early 90s, was in many ways an adjunct to criminal work, and in some ways it still is. I say that because (especially in the beginning) compliance really emanates from the Sentencing Guidelines, which are criminal; the Sentencing Guidelines guide judges in terms of sentencing for crimes. When companies got in trouble, whether they were under investigation or under indictment, they would often go to compliance to better their situation with prosecutors, or because the SEC or another agency insisted as part of a consent decree.

From my practice perspective, what I think is the mistake that is sometimes made is that outside compliance professionals, and in-house too, perhaps forget that their client is the company. Keeping in mind that the client is the company means keeping in mind that the client is not the general counsel or the CEO or high-level management. Every outside lawyer is subject to that issue, not just in the compliance field.

Rebecca Walker's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Christopher Vigale

These excerpts are taken from our interview of Christopher Vigale, who told us about being an outside compliance analyst.

Essentially, I help figure out how to relay particular supplies by looking at who the client is and assessing the risk involved (particularly the risks the client will face). I examine how other similar companies perhaps dealt with the same issues, and whether or not these issues pushed them towards compliance. Just basic client work.

…it was somewhat upsetting when I first started and had to do a synopsis of Sarbanes-Oxley. It is a huge piece of legislation, with no opposition, in response to massive scandal. And it’s not specific to the corporate world. Sarbanes-Oxley shouldn’t have come out because of Enron; I saw the changes instituted by Sarbanes-Oxley and wondered where was it all before? Everyone knew about those things [scandals], and finally something was done, but it was a little too little, too late. With more involvement and attention, it could’ve all been helped.

Christopher Vigale's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

It’s Official: The new book is available at SCCE!

Building a Career in Compliance and Ethics is now available in SCCE’s store!

The book also shows up on the main page.
If you prefer to order by fax, there is a pdf available for download/viewing.

The price for both SCCE members and non-members is $29.95.


Spread the word, and order your copy here!


(A new banner link will be added above all posts, joining the one for Amazon. This post will also be added to the sidebar in the Important Posts and Working for Integrity Links sections.)

Article Alert: SmartPros considers a compliance career

Our newest article promoting working in the field is now up at the SmartPros website.

From their website:

SmartPros Ltd. is an industry leader in the field of accredited professional education. Its products and services are primarily focused in the accredited professional areas of corporate accounting, financial management, public accounting, governmental and not-for-profit accounting, banking, engineering, and ethics and compliance.

The article, Have You Considered a Compliance and Ethics Career?, was written by Joshua Leet.

The article shows up on their primary resource page and on pages for Students, Ethics and Compliance, HR, and Corporate Finance. It also went out in their Career Newsletter today, and will be in their Monday "News & Insights" newsletter.

Marshaling Integrity - Winthrop Swenson

This excerpt is taken from our interview of Winthrop Swenson, who we spoke to about working as an outside advisor, his experiences as Sentencing Commission Deputy General Counsel, and his work with a Big Four firm

At the Commission, the job was to write a series of laws that would apply when organizations (not just corporations but including corporations) are sentenced in federal court for crimes. There was no prior existing law of any kind that dealt with this specific area, so we had to create a brand new scheme and framework for what sentencing of corporations should look like. We got input from the private sector and from governmental entities, and came up with the framework that included a model for compliance and ethics programs. That took quite a while and many, many drafts, on which we got public and informal comment along the way. When the Guidelines came out, they were regarded as fairly experimental, so I spent a lot of time going out and talking to particularly the business community about the Guidelines (what their intent was) to make sure that everybody had gotten the word.

Winthrop Swenson's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Roy Snell

These excerpts are taken from our interview of Roy Snell, a former compliance officer and CEO of HCCA & SCCE.

As past president, and now CEO of this organization, I have talked to thousands of compliance officers, many of whom are frustrated, and they ask what they can do. The problem is they can’t facilitate change. My answer isn’t, “go study the law”; they already know the problem. The answer is frankly a difficult one. If you can’t get these people to listen to you, and if you can’t facilitate change, then you’re probably in the wrong profession.

Because compliance and ethics frequently involve laws, rules and regulations, employers assume that the best background is a legal background. The problems brought to our attention (and that we’re trying to fix) don’t require as much understanding of the law as they do an understanding of human nature and the challenges associated with getting high-ranking officials to do things differently. It requires administrative experience, administrative savvy, leadership skills, communication skills, negotiation skills, and collaboration skills.

…I would say 90% of the challenge of the compliance job has nothing to do with understanding the laws. Furthermore, you have a legal department, you have an outside legal department; there’s a plethora of people who can help with the legal analysis.

Roy Snell's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Daniel Roach

These excerpts are taken from our interview of Daniel Roach, who we spoke to about working as a health care compliance officer.

One particular area that is unique to health care is the whole issue of quality and medical necessity. That is an area where we do some work from a compliance perspective in the organization to make sure that we have effective peer review processes, and to make sure that we’re providing only medically-necessary services.

I really think that organizations who want an effective compliance program should try to get a compliance professional or two on their board. Or at least get one on the committee of the board (whether it’s the audit committee or the compliance committee) that oversees the compliance processes in the organization. Sarbanes-Oxley requires organizations to have a financial expert on the audit committee, and if the audit committee is where the compliance function ultimately reports, then it makes sense to have compliance expertise on that committee as well.

Daniel Roach's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Arjun Rajaratnam

These excerpts are taken from our interview of Arjun Rajaratnam, a compliance officer in the pharmaceutical industry.

It’s a challenging job. It’s a very challenging job. We are expected to create huge change across vast organizations, from a relatively, less-than-high-profile position. We’re getting to have more and more profile and more access, but nevertheless, we’re not as powerful as we’d like to be, but even with that lack of power, we’re expected to make great changes. I moved in from Environmental Law, and from the environmental lawyer perspective, compliance, at least the legal part of compliance, is easy. I’d dealt with hundreds of thousands of regulations, very gray and complicated ones, so trying to have a handle…it was a great background to be a generalist across 15/16 legal areas.

Pharmaceutical compliance officers are a very hot commodity. I get a headhunter call almost every other week for another compliance position in the pharmaceutical industry. All the pharmaceutical companies are expanding their compliance departments for obvious reasons, and so there’s a high degree of job security in the pharmaceutical compliance field. Again, like everything in a good capitalist economy, I expect that to peter out with time. As more and more people jump into it, and more and more people who are not compliance officers get a little training and are able to label themselves compliance officers, we’ll start to see the supply and demand equation change.

Arjun Rajaratnam's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - William Prachar

These excerpts are taken from our interview of William Prachar, a long time compliance officer and current outside advisor.

To be effective, you have to understand the overall culture of the organization. The field certainly has HR elements, but it’s not HR, and I think it does it a disfavor to compare it to HR. Certainly, on the helpline side, most of the complaints and issues that come up are HR complaints, but the fact that compliance officers develop a program means they have to understand the business. In fact, I think some of the best ethics officers come out of the business side of the house…

[t]he first month you’re on the job, even before you come to the job, do not think about ethics and compliance. This is the thing I tell all people that get into the business. You need to think about the business of the company. What does it do? What do they make? What are the pressures that are on people in this business? You’ve got to understand the business, because if you don’t understand the business, you can’t understand how to effectively help. What you need to do is design some kind of program that’s going to have some effect on the overall culture of the organization, and the only way you can do that is to understand what the people do.

William Prachar's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Bob McCarter

These excerpts are taken from our interview of Bob McCarter, an executive at a help line provider.

This role gives me the opportunity to meet with clients that are making decisions about their compliance program. I’m giving them things to think about as they’re starting their compliance program or as they are fine-tuning or refining it. It’s important to have a good framework or a good structure within your organization. An effective compliance program brings a lot of elements together: an awareness of the regulatory environment; good internal awareness, making sure that you have good controls in place.

We encourage all of our individuals, whether they’re salespeople coming on board, or professional services [people], or even employees in the contact center, to just be curious and ask questions. Often we find that in interactions with our clients, we can come up with good solutions if we both sit down and brainstorm together.

Bob McCarter's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Working for Integrity mentioned at ComplianceWeek

The current issue of ComplianceWeek includes a guest column of interest.

Working for Integrity interviewee Donna Boehme has written a piece entitled "Building a Compliance and Ethics Function" and in it she cites the original book. The mention comes in the "Institutional Protections" section.


The article is available to ComplianceWeek subscribers here.

Marshaling Integrity - Stacy Martin

This excerpt is taken from our interview of Stacy Martin who talked about working as a privacy officer.

When it comes to privacy, things are not always black and white. Privacy means different things to different people and people should take privacy more seriously. I find it very gratifying to be involved in an open and balanced discussion with someone who is also passionate about privacy. At the end of the conversation, we may not always agree, but nor do we have to. Great progress can be made by simply engaging in thoughtful conversation so that opposing sides can gain a greater understanding of each other’s issues.

Stacy Martin's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - James Lukaszewski

These excerpts are taken from our interview of James Lukaszewski, an experienced outside crisis response advisor.

There is an inherent resistance to admit being wrong, an inherent resistance to cave in to the do-gooders. There’s a wonderful article in Harvard Business Review, and it raises the question about where business schools went wrong. What the authors talk about in that article is that business schools have begun to focus heavily on being scientific—everything has to be measurable or countable; if it isn’t, it doesn’t matter. When you work and live that way, then in essence you factor out the human part of the business; what you factor out, in their area, is the professional part of being a businessperson—judgment, morals, and better behavior.

One thing I’ve learned is, after they pass the age of 13 it’s really hard to change people’s thinking and behavior! I keep my expectation levels realistic. If I can make modest, incremental changes in people’s behavior—especially at the level I work—there will be monumental impact on the organizations these people run. I look at this as an opportunity to be helpful, as an opportunity to do something worthwhile that benefits a lot of people, yet requires very little energy on the part of these very senior people. It does involve significant commitment and discipline, an enormous change in attitude, and an enormous change in thinking. Even if the issues don’t involve something as dramatic as Sarbanes-Oxley, every issue I’m involved in has its ethical parameters.

James Lukaszewski's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - John Lenzi

These excerpts are taken from our interview of John Lenzi, who we asked about working as an assistant compliance officer.

Part of the responsibility of the compliance officer in our corporation is to make sure that we’re not the only ones responsible for compliance and integrity...we’ve built a team called the “Compliance Leadership Team” (it has representatives from each function) that is very similar to what each of our operating companies has done, so that when you undertake a department and company risk assessment, you and I aren’t doing it as outsiders to finance, or outsiders to HR. You have HR people working through the process that you developed, to identify risks for their department, and risks that are shared by everybody...

There’s a difference between program funding and Sarbanes-Oxley funding, which really might focus more on the finance systems and accountabilities therein to make sure that everything is proper and accurate when you file your quarterly and annual report. There you’ve seen a lot in the press where companies and executives are saying, “It’s too demanding on companies. It’s too difficult and too time consuming and too expensive,” and some companies are even suggesting it’s not necessary. But it’s the law, and the important point is to get it right in the end.

John Lenzi's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Alan Leibowitz

These excerpts are taken from our interview of Alan Leibowitz, a former Director of Environmental, Safety and Health, ITT.

What we’re going to find as we go forward as a profession is that it’s going to be less and less about being the policeman/the trainer, and more and more involvement in the strategic, operating and planning processes for these different organizations we work with. Ultimately, we’ll get to the level where each of the critical decisions made within an organization passes through or in conjunction with somebody whose focus is compliance, ethics, or ESH.

You can get a lot done without having to be abusive about it. I’ve seen people who think that they’re the cops, and that they need to have that sort of police mentality, when that’s not really very effective. You’re asking people to do things they won’t otherwise want to do, and they wouldn’t choose to do. There’s a resource cost, either in dollars or time. And you have to make sure everybody understands you’re not doing it to build an empire or for personal aggrandizement, but that you truly have their interests and the interests of the organization at heart.

Alan Leibowitz's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity – Jeffrey Kaplan

It's been a few days since the last excerpt (so as to leave the Amazon post prominent--now the new button link should take care of that). From this point on through the end of the month, expect an excerpt or two every day leading up to the publication of the new book. On the 28th, expect excerpts from the five interviews also included in Building a Career in Compliance and Ethics.

These excerpts are taken from our interview of Jeffrey Kaplan, an outside compliance lawyer.

I also do compliance program assessments. That’s an assessment for a board of directors or senior executives as to how effective the company’s compliance program is. I’ve done those both individually and with a consulting firm called the Ethical Leadership Group, with whom I partner for certain engagements. These assessments entail understanding the company’s risks and how the company has responded to those risks in its compliance program. By talking to executives, employees and focus groups (and through other means), we assess how effective the response seems to be to the risks, and make recommendations as to what else can be done through the compliance program to address those risks.

I’ve certainly seen the field grow, seen companies that never to my knowledge were involved in this embrace it, at least to the extent of hiring compliance and ethics officers and having some kind of program. I’ve certainly seen it rise to a higher level of attention than it had in the early days (meaning the early to mid 1990s). I’ve seen more board involvement, which is obviously a good thing, and senior executives’ involvement, also a good thing. All of those things are good and suggest a field that has not yet come of age, but is heading in that direction. The other side of the coin, however, is that the experience of the late 1990s showed that many companies adopted the programs with great fanfare, and yet gradually lost interest in them. The compliance and ethics officers who were hired saw their positions diminish in importance along with the diminishing commitment of the companies.


The difficulty right now for anyone considering the field is to get a sense of whether the renewed interest—which is spawned by Sarbanes-Oxley, the revised Sentencing Guidelines, and related events—represents a fundamental long-term change, or just a bigger version of what happened in the 1990s, when there was, at least at many companies, initial attention which then diminished.

Jeffrey Kaplan's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Big News: The new book is available for pre-order on Amazon!

We just found out that Amazon.com already has the book up for pre-order! You can order a copy now, and it will be shipped on February 28th.

As is often its way, Amazon.com has discounted the book, so rather than paying the full $29.95, you can pre-order the book now for just $19.77. That's a pretty significant discount (don't worry, we still get just as much from Amazon).

We're very excited to see our book up on Amazon and look forward to the new people it will draw to the field.

So spread the word, and order your copy here!

SCCE News: More on the 6th Annual C&E Institute

SCCE's 6th Annual
Compliance & Ethics Institute
(From a February 5th email)

September 9-11, 2007 | Sheraton Hotel, New Orleans

Call for Speakers
Proposals are due Friday, March 2, 2007

SCCE is currently accepting proposals for breakout sessions at its 2007 annual institute.

The SCCE annual institute is the primary education and networking event for professionals working in the compliance and ethics profession today. Over 500 compliance professionals will gather at this meeting to hear the latest methods and strategies for developing and improving corporate compliance and ethics programs.

For submission information, please visit SCCE's Web site or contact:

Kathy Aro
Society of Corporate Compliance and Ethics
6500 Barrie Road, Suite 250
Edina, MN 55435
Tel: 952-405-7925
kathy.aro@corporatecompliance.org

The submission deadline is Friday, March 2, 2007.

Marshaling Integrity – Pat Gnazzo

This excerpt is taken from our interview of Pat Gnazzo, who discussed his experiences and observations from working as a compliance officer.

I think most companies are reluctant to take on somebody that’s an unknown and put them into a position of confidence immediately. Then that individual is taking in issues where the company potentially has problems, and they have to rely on that individual to help them solve problems, rather than cause more problems. A better example to say is “The devil you know is better than the devil you don’t know.” So unless you have real need—meaning you’re under a deferred prosecution agreement or the government is forcing you to hire somebody that is higher profile—you’re going to want somebody that is a known commodity to you in your organization and somebody you can rely on.

Pat Gnazzo's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Paul Fiorelli

This excerpt is taken from our interview of Paul Fiorelli, a professor and director of a business ethics center.

At the center, we work with faculty to try to increase their familiarity with business ethics; we’re trying to encourage them to integrate business ethics across the business curriculum. In addition to that, we also provide an outreach service for the business community, running a number of events during the year.

Paul Fiorelli's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Donna Boehme

This excerpt is taken from our interview of Donna Boehme, who we contacted to learn about her experiences working in compliance "overseas".

As you are probably aware, the industry could be viewed as having its birth in issues arising out of the defense industry scandals of the 70’s. But as the industry has matured, meeting the overall seven elements of an effective compliance program has become more important, in addition to addressing the specific, regulatory compliance issues that you might see in the highly regulated industries, like pharmaceuticals or defense. In Europe there has been a traditional emphasis on ethics which historically manifested in aspirational mission or value statements, but in a recent study the majority of leading European companies also had codes of conduct. So the US no longer has the market cornered on compliance.

Donna Boehme's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

SCCE News: 6th Annual C&E Institute

SCCE's 6th Annual
Compliance & Ethics Institute
(From a January 30th email)

September 9 – 11, 2007 | Sheraton New Orleans Hotel

Mark Your Calendars!

The Society of Corporate Compliance and Ethics (SCCE) announces that its 2007 Compliance and Ethics Institute will be held in New Orleans from September 9–11, 2007.

Featuring nearly 40 breakout and general sessions, SCCE’s Compliance & Ethics Institute is SCCE’s flagship event and is the primary educational and networking event for professionals working in the compliance and ethics profession.

In addition to bringing attendees an outstanding educational program, SCCE invites attendees to fall in love with New Orleans all over again! The most celebrated and historic core of New Orleans is as rich, charming, and welcoming as ever, and we invite you to celebrate the traditions that make New Orleans one of America’s most unique, authentic, and enthralling destinations.

The meeting will take place at the Sheraton New Orleans Hotel. Located on historic Canal Street, the Sheraton New Orleans Hotel is at the heart of the Big Easy. It features majestic views of the French Quarter and Mississippi River and is only a short walk to Bourbon Street, Riverwalk Marketplace, Canal Place, JAX Brewery, Harrah's Casino, and all the world-famous restaurants and live music clubs of the Vieux Carré.

Visit SCCE's Web site regularly for event updates.

Marshaling Integrity - Margaret Bavuso

These excerpts are taken from our interview of Margaret Bavuso, who shared her experiences as a compliance director and investigator and as an outside advisor.

Compliance work is very interesting. The politics in every corporation impact the effectiveness of any compliance program, and very often the politics are based on personality. Everybody has to know what their own threshold is as to what they’re willing to deal with.

…the last thing you want is a program that sits on the shelf. You want a program that actually works and prevents wrongdoing. And then when there is wrongdoing, you actually have a process for investigating and taking action. The transition from inside to outside gave me that benefit.

Margaret Bavuso's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Marshaling Integrity - Scott Avelino

These excerpts are taken from our interview of Scott Avelino, who we asked about providing compliance advice from a Big Four firm.

The range of things that we’ve been involved with have been all over the map, anywhere from helping companies develop a simple code of conduct through to helping a company audit their compliance with that code of conduct worldwide and report the results publicly, and all things in between.

…in the wake of Sarbanes-Oxley, there is an increased obligation on behalf of the external auditor to, as part of its audit of internal control (which is a mandate under Sarbanes-Oxley 404) evaluate the effectiveness of traditional compliance program elements. In the audit world, these are often referred to as anti-fraud programs and controls, but they’re generally the same control elements: codes of conduct, hotlines, training, enforcement mechanisms and the like.

Scott Avelino's interview is included in Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field.

(All interviewees spoke to us about their own personal experiences and opinions; interviewees were not acting as a spokesperson or otherwise representing their current or former employers.)

Assorted News

As we get closer to the release of the new book, we will post some small excerpts from the books to whet your appetite. Check back regularly. In the meantime...


Interesting Ethics News
The University of California has taken a bold step and decided to have all its employees take an ethics course.


Article Alert
As mentioned in a previous post, Joshua Leet wrote an article covering the SCCE's CCEP certification program for ethikos. The issue containing that article is out now. (The article is not online - a copy of ethikos must be ordered.)

You can also expect another article online elsewhere in the near future as part of our efforts to promote the project. More on that in the coming month.


Interview Update
Several of the individuals interviewed for the books have since changed jobs or received promotions. Recently, Rodney Smith informed us that while he is still with the Timken Company, he has been promoted to be Sr. Associate Relations & Safety Analyst at Timken's Faircrest Steel Plant. He is excited about his new role, though it is less of a broad compliance role.

Other interviewees whose information has changed since the first book include:
-Donna Boehme, now acting as a Special Advisor to CSLG and its clients, among other things
and
-George Wratney, closed his Wratney Ombuds Concepts

First Look - New Book Cover

Below you will find the full cover (front and back) of our new book. Made up primarily of material from Working for Integrity: Finding the Perfect Job in the Rapidly Growing Compliance and Ethics Field, this book will appeal more to students, young professionals, and those with a casual interest in the field.

So here you have it, Building a Career in Compliance and Ethics: Find your place in the business world's hottest new field.
Available February 2007 from the Society of Corporate Compliance and Ethics.
(Click each image for a larger version)

SCCE News: Education and Recognition

SCCE 2007 Educational Opportunities
(From a January 3rd email)

SCCE 2007 Educational Opportunities

Register Now!

SCCE is the premier provider of compliance and ethics educational events. Faculty is composed of industry experts from around the world who represent the corporate environment, academia, government, and the law. Attracting hundreds of compliance professionals each year, SCCE events also provide unparalleled networking opportunities. Current program include:

Academy:
The SCCE Academy is a four-day intensive training program with the optional CCEP exam on the fifth day. Academies are designed to address USSC compliance elements in detail and better prepare interested parties for the CCEP exam. They are designed for participants with a basic knowledge of compliance concepts and some professional experience (6–18 months) in a compliance function.

Date/Location:

Dallas: March 26 – 29, 2007 (optional CCEP exam on March 30)

Click here to learn more

Workshops:
Workshops are two-day programs designed to provide the practical information compliance professionals need to create and maintain compliance programs in a variety of industries. Workshops run on Thursdays and Fridays and are followed by the optional CCEP exam on Saturday mornings. For your convenience, the 2007 workshops will be held in four locations throughout the country.

Dates/Locations:
Chicago: March 15 – 16, 2007 (optional CCEP exam on March 17)
New York: March 22 – 23, 2007 (optional CCEP exam March 25)
Los Angeles: April 12 – 13, 2007 (optional CCEP exam on April 14)
Dallas: May 17 – 18, 2007 (optional CCEP exam on May 19)

Click here to learn more

Audio Conferences:

The McNulty Memorandum

SCCE will present its first-ever web conference on January 18, 2007 to discuss the ramifications of the memorandum released on December 12, 2006 by U.S. Deputy Attorney General Paul J. McNulty

Expert speakers for the web conference are Gabriel L. Imperato, Managing Partner at Broad and Cassel and Judith A. Walz, Partner at Foley and Lardner.

Date/Time: January 18, 2007 | 12:00 Central Time (90 min.) | 1.2 CEUs

Click here to learn more

Credits earned at SCCE events will count toward the credits required to sit for the certification exam.

Please visit the SCCE website at www.corporatecompliance.org for program updates!

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SCCE Announces Annual Journalism Award

(From a January 10th email)

SCCE has established a new annual journalism award. The award will recognize a journalist who shows insight into the compliance and ethics field, and who promotes public and governmental recognition of the field and/or the value of compliance and ethics programs. The award will be given to a specific journalist or team of journalists.

Submissions may include printed or broadcast materials. SCCE prefers to have permission to reprint or reproduce the material on its Web site. The award recognizes contributions to the compliance and ethics field made at any time in the past; it is not limited to work published in any given year.

Criteria:
Submitted works must have a major focus on corporate compliance and ethics programs and/or compliance and ethics professionals—they should not only be about corporate crime, corporate governance, enterprise risk management, corporate social responsibility, or similar areas. Works sponsored by or focused on the products or services of any one service provider, such as a helpline service, software provider, or online training provider, are not eligible. Works appearing in publications intended solely for the compliance and ethics field (i.e., the trade press) are not eligible, unless the work has had a public impact. Blogs, Web sites, and books will not be considered.

Nominations:
Nominations may be submitted by anyone, including self-nominations. The nomination must include a copy of any material which forms the basis of the nomination and background information on the nominee. Selection decisions will be made by the SCCE. All determinations are final.

All nominations may be e-mailed to Kathy Aro: kathy.aro@corporatecompliance.org

Deadlines for submissions:
All nominations must be received by Friday, January 26, 2007.

The journalism award will be presented at the SCCE’s annual awards dinner in Chicago, IL, on Sunday, April 22, 2007, from 6–9 pm.

Visit SCCE’s News Room for this and other SCCE announcements.

Book Cover Delay

Well, obviously the new book's front and back covers are not posted yet, and for good reason:
We don't have the finalized images yet.

Hopefully we will have them up this next week. If not, expect them sooner rather than later.

In the mean time, we will be posting various compliance news and perhaps a few tidbits from the book(s).

Links - Jobs and Blogs

They are a bit later than planned, but there are now some more links in the sidebar scrollboxes, specifically sites listing compliance jobs, and some blogs we came across related to compliance and ethics. We don’t specifically recommend any of them, nor do we check them all regularly, but most of you will probably find something interesting.

The new job listings sites are shown below (and will be in the Compliance and Ethics Link section of the sidebar), but the blogs will only be listed in the sidebar, in the new Relevant Blogs section.


Job Listings/Searching:

Compliance Week - General "Help Wanted Listings" are provided. There aren't too many, but if nothing else, they may serve as good examples.

HCCA - The Health Care Compliance Association lists various job openings in the Health Care field.

NSCP - The National Society of Compliance Professionals offers a "Job Line" section on its site.

SCCE - The Society of Corporate Compliance and Ethics has a page of listings.

ECOA - The Ethics and Compliance Officer Association offers JobLink, but you have to be an ECOA member to access it.


U.K. only sites - These two sites cater to compliance job seekers in the United Kingdom.

Compliance Online - ComplianceOnline.co.uk, the "UK financial services compliance portal" lists almost 200 jobs.

ICA - The International Compliance Association has various jobs sorted by region.


Beyond all of these specific sites, you will find countless compliance and ethics jobs listed on the larger job search sites (Jobster, Monster, Yahoo, etc), and you may also find that some "headhunter" firms also deal with compliance.

Big News! A New Installment in the Project

As some of you may know, we have long planned a smaller, more mass market version of the book.

We have just finished looking over the galley proofs of that book, and it goes to press next week.

The new book, Building a Career in Compliance and Ethics: Find your place in the business world's hottest new field, will sell for only $29.95 and will be published next month, February 2007.

It will of course be available through SCCE, but we are not sure yet where else you may be able to get a copy. We will keep you updated.

Below, we have included the Table of Contents of this new book, and next week, we should have up the front and back covers of the book, so be sure to check back then.

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Building a Career in Compliance and Ethics
Table of Contents


Contents

Preface

1. What Is This Field?

2. Why Should I Go into This Field?
Appendix 2A: Should I Go Into Compliance and Ethics? Some Questions to Ask Yourself

3. How Do I Get into This Field?
Appendix 3A: Resume Builders: Things You Can Do to Advance in the Compliance and Ethics Field.

4. What Are the Jobs in Compliance/Ethics?
Appendix 4A: What’s in a Name? Titles and Positions in the Compliance and Ethics Field

5. The Top Job In-house: Compliance Officer

6. Compliance Careers for Lawyers

7. Compliance Work in Privacy and Data Protection

8. The Voices of Experience: Advice from Those in the Field
Odell Guyton, Microsoft’s Director of Compliance
Rodney Smith, In-House Environmental, Health, Safety and Ethics Analyst
Joseph "Joe" Murphy, Former In-House Compliance Lawyer, outside advisor
Linda Lipps, In-House Compliance Officer
Richard Gruner, Law Professor and author in compliance

9. What Training and Certifications Are Available for Compliance Professionals?
Appendix 9A: Model Curriculum
Appendix 9B: University of Pennsylvania Corporate Lawyering Seminar: Compliance Basics
Appendix 9C: Certified Compliance & Ethics Professional (CCEP) Program Overview - Excerpts from the Society of Corporate Compliance and Ethics "CCEP Candidate Handbook"

10. Selling Compliance (and the Importance of Your Job) to Management
Appendix 10A: Benefits of a Compliance Program

Appendices
Appendix A: Glossary and Acronyms in Compliance (from Integrity Interactive's Compliance Primer)
Appendix B: Sentencing Guidelines Definitions
Appendix C: Where Can I get More Information and Advice?
Appendix D: Compliance: War story reading
Appendix E: Ethics Centers
Appendix F: There Is More

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