“Wells Fargo Faces More Woe Over Client Data,” The Wall Street Journal, May 18, 2018 B1. Another shoe drops at Wells Fargo (when will it ever end?) after disclosure that employees in the wholesale business (non-consumer) banking side changed and added customer information without approval. Reason: to meet a compliance deadline.
Is there another organization with so many compliance failures? It started with consumer banking and credit cards and now seems to have permeated the entire enterprise. Is it risky to call this an enterprise? What influenced their behavior? Why are the directors not in the dock? Weren’t they in charge of establishing and ensuring the culture of compliance? This is a bank, for God’s sake.
Is it easier to find someone who was or wasn’t involved in some type of bad behavior at Wells Fargo?
Filed under Accuracy, Board, Compliance (General), Controls, Corporation, Culture, Culture, Directors, Duty, Duty of Care, Employees, Governance, Internal controls, Managers, Oversight, Oversight, Supervision
It’s bad enough trying to control your own employees, and those of your agents (and vendors). But how do you control the employees, agents, and vendors of your various affiliates and ventures? Do you all have the same Code of Conduct? The same policies on a whole host of sensitive matters?
“KPMG Scandals Stay Local,” The Wall Street Journal, March 8, 2018 B10. KPMG deals with alleged non-compliance at three international affiliates involved in auditing.
Does a client know the difference? Do you ask prospective consultants about the compliance history of the larger firm? Do you exercise enough control to also get liability?
Filed under Board, Compliance, Compliance, Compliance Verification, Controls, Duty, Governance, Internal controls, Managers, Oversight, Third parties
“‘Success Theater’ Masked Rot at GE,” The Wall Street Journal, February 22, 2018 A1. GE’s CEO may have been too optimistic. “This culture of confidence trickled down the ranks ….”
If the top boss has rose colored glasses, that view apparently permeates the organization. If he or she reacts badly to bad news, do people stop bring bad news?
One principle of compliance is that the tone at the top matters. Does the CEO’s tone build filters that prevents him/her getting the facts? Are the resulting wounds self-inflicted? Where was the Board?
Filed under Access, Accuracy, Board, Communications, Controls, Culture, Data quality, Duty, Employees, Governance, Internal controls, Managers, Oversight, Oversight
“Faked Data at Issue Again in Japan,” The Wall Street Journal, November 25, 2017 B1. Mitsubishi Materials continued to ship car, plane, and power-plant parts to 200 customers (including in the US) while factory workers were fudging quality data on rubber gaskets and copper products. As is common, they sat on the news for a while.
This follows similar stories about Kobe Steel and Nissan Motors. So much for the much-vaunted quality initiatives in Japan. These types of problems “have deep roots in Japan Inc.’s governance problems,” which rely on decentralized and largely independent operations.
If there’s a problem somewhere else in your industry, you probably have it, too; you just haven’t found it yet.
Filed under Accuracy, Board, Compliance, Controls, Corporation, Culture, Data quality, Directors, Duty, Duty of Care, Employees, Governance, Internal controls, Managers, Oversight, Protect assets, Supervision, To report, Vendors
“CEOs Make Protecting Data a Top Goal,” The Wall Street Journal, October 13, 2017 B4. Unfortunately, the focus is on cyber-security rather than the broader information risk profile. While this affect CEOs’ email habits, as they are phishing targets?
While this is a start, do CEOs really understand how much their company’s proprietary information is worth? Or their duty to protect the company’s assets (people, physical equipment, cash, and information)? Why not?
And where are the boards? Don’t they have an overarching duty to oversee the major risks the company is facing and to make sure there’s an effective program in place to address?
I hear the violin. Is Rome burning?
Filed under Access, Board, Compliance, Compliance, Compliance Verification, Controls, Corporation, Culture, Directors, Duty, Duty of Care, Employees, Governance, Information, Internal controls, IT, Managers, Oversight, Oversight, Ownership, Policy, Protect assets, Protect information assets, Security, Value
What does it say about a company’s culture that allows a sexual predator to continue to run the company for years? What other non-compliance with ethics and law will we find? Not only there, but at every other company in the industry? Nobody reported this? Where were the policies and the audits? Where were the lawyers? Where was the press?
“Weinstein Co. Board Fires Harvey Weinstein, Citing Sexual Misconduct Allegations.” The Wall Street Journal on-line, October 8, 2017.
Filed under Board, Compliance, Controls, Corporation, Culture, Culture, Directors, Duty, Employees, Governance, Internal controls, Managers, Oversight, To report
“A Hot Startup Misled Advertisers,” The Wall Street Journal, October 13, 2017 A1. Outcome Health apparently misled advertisers as to how many units their ads were appearing on. The investigation continues.
How would your employees react if ask to provide inflated numbers to potential customers? How would your investors react after a story appears on page one, above the fold? Probably reflects in the valuation of the company. And what about your company’s extensive political contacts?
Filed under Accuracy, Board, Communicate, Compliance, Compliance, Compliance, Compliance Verification, Controls, Corporation, Culture, Culture, Data quality, Directors, Duty, Duty of Care, Employees, Governance, Inform market, Inform shareholders, Information, Internal controls, Investor relations, Managers, Oversight, Oversight, Policy, Protect assets, Protect information assets, Use, Value