You manage what you measure

If you are serious about imposing a requirement, measure compliance with that requirement and publish the data.

“OPEC Data Show Compliance With Production Cuts,” The Wall Street Journal, February 14, 2017 B9. OPEC confirms 90% of its members are complying with agreement to curtail output.

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Filed under Collect, Communicate, Compliance, Compliance, Governance, Oversight


What happens when you have a duty to disclose information to your shareholders and you try to hide that disclosure?

“Fox Faces Probe In Ailes Settlements,” The Wall Street Journal, February 16, 2017 B3.  Company incurs at least $35 million to deal with sexual harassment claims involving the former CEO.  But maybe they didn’t tell their shareholders enough information about these payments.

If this is happening on a big issue, what does it say about the reliability of internal reporting on other issues?  Is legerdemain acceptable corporate behavior?

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Filed under Access, Accuracy, Board, Collect, Communicate, Compliance, Compliance, Compliance, Corporation, Data quality, Directors, Duty, Governance, Inform market, Inform shareholders, Information, Management, Oversight, To report, Uncategorized, Value

Conundrum wrapped in enigma

How many levels of information governance, or the lack thereof, are implicated in the recent dust-up over Michael Flynn?

“Spies Keep Intelligence From Trump,” The Wall Street Journal, February 16, 2017 A1. Did US intelligence officials really hide information from the President?

Mike Flynn may or may not have discussed sanctions with the Russians in December.  Trump may or may not have been advised of this in December.  Mike Pence may or may not have been advised.  Pence said that he had spoken with Flynn and that sanctions hadn’t been discussed.  Apparently, there is a classified transcript of Flynn’s phone call, possibly captured in violation of US law.  Contents of that reported transcript were possibly released to the media.  Certain information allegedly withheld from the President.

What information is important to your company?  What controls do you have in place to prevent that information from being leaked?  How do you find the leaker?  What steps do you take when you find him or her?  How do you repair the damage from the leak?

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Filed under Controls, Duty, Employees, Governance, Government, Internal controls, Management, Oversight, Protect, Protect assets, Use

It’s a start

“Wells Board To Cut Off Bonuses,” The Wall Street Journal, February 9, 2017 B2. In the continuing saga of the Wells Fargo account-cramming saga, the Board may withhold or reduce bonuses to some senior execs.  This follows the sacking/early retirement of the former CEO.

So, the shareholders pay $185 million in fines and settlements and the CEO “retires.” The Board reduces or cancels senior executive bonuses.  Boo hoo.

What pain to the Board for their failure to catch this?  Does their compensation get reduced?  Should it?

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Filed under Board, Compliance, Compliance, Controls, Culture, Directors, Duty, Employees, Governance, Internal controls, Investor relations, Managers, Oversight, Oversight, Supervision

Man bites dog

You would expect law enforcement candidates (and the people teaching them) to be compliance hawks.  Not.

“Cheating Found at Police Academy,” The Wall Street Journal, February 4, 2017, A2. [This appeared under the heading “U.S. Watch” in the print edition; it is not online.]  Evidence of cadet and instructor misconduct in testing at Pennsylvania State Police Academy, and deficient training.  The good news is that inspectors found it.

How good is your training?


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Filed under Compliance, Controls, Duty of Care, Governance, Internal controls

Serious about Quality?

Is information important in your company?

“Nuclear Supplier Hit Over Safety,” The Wall Street Journal, February 7, 2017 B3.  A key supplier of equipment to nuclear power plants was investigated, and “extensive management weaknesses” were found to have led to the coverup of manufacturing problems at a plant in France.  Manufacturing records “had been haphazardly altered.”

How can you have quality (or safety, or legal or policy compliance) when people fudge the underlying information that you rely upon?  How far up the chain do the management weaknesses extend?

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Filed under Accuracy, Collect, Controls, Data quality, Duty, Employees, Governance, Information, Internal controls, Management, Managers, Oversight, Protect, Value


Normally, I tie to an article in The Wall Street Journal, but couldn’t find this news items there.  Today’s post is based on an article yesterday from Corporate Counsel.

The former General Counsel of Bio-Rad Laboratories in California got fired in 2013, soon after he reported to the company’s audit committee on possible FCPA violations.  He claimed whistleblower protections under Sarbanes Oxley.

Jury finds for plaintiff; $5.8 million in back pay and $5 million punitive damages.  Company had already paid $55 million to settle FCPA allegations.

Interesting implications for compliance, audit committees, whistleblowing, and attorney-client privilege.

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Filed under Board, Compliance, Compliance, Corporation, Duty, Employees, Governance, Lawyers, Legal, Privilege, To report