Secondary compliance

“More Firings at BofA Amid Misconduct Claim,” The Wall Street Journal, March 1, 2018 B1.  Two employees fired for interfering in investigation into allegations of sexual misconduct by another employee.  They may have gotten together to get their stories straight.

What does this say about culture at BofA?  Not just that there’s another instance of alleged sexual misconduct, but also that people would think they could influence the process?

Again, how do you protect against this type of behavior?  Is it enough to just publicly fire the violators?  Do you teach on the perils of interfering with an internal investigation?  This is, in all likelihood, solely a violation of policy (assuming you can find a policy that governs).  Maybe bad ethics?


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Filed under Board, Compliance, Compliance, Controls, Corporation, Culture, Culture, Duty, Employees, Governance, Internal controls, Oversight, Supervision, To report

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