Category Archives: To report

Telling the truth is a journey

“Facebook Details Data Sharing,” The Wall Street Journal, July 2, 2018 A1.  Facebook “expands” its answer to the question, “Who else saw our data?”  Apparently, a lot more people than Facebook said originally.  A bunch of special deals and exemptions from Facebook’s “policy.”

So, apparently Facebook does not have a personal relationship with the truth, but they sure have your information.

One expects further revelations in the months ahead.

Takeaways:

  • Lying is not an effective communications strategy
  • When you’re being investigated, either tell the truth or say “I don’t know.”
  • The only person who can grant an exception to a policy is the person who issued the policy (or their superior)
  • Strictly enforce your company policies, or they won’t help much
  • Treat my data with as much care as you treat your data
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Filed under Accuracy, Communications, Compliance, Controls, Corporation, Culture, Duty, Governance, Internal controls, Investor relations, Oversight, Policy, Privacy, To report

Warnings v. Controls

People knew the shooter in Annapolis was a danger to the newspaper.  Employees were warned.  Police investigated his on-line comments, and determined he is not a threat.  Employees were told to call 911 if they saw him.

Five years later, he kills 5 people with a shotgun.

“Newspaper Warned About Shooter,” The Wall Street Journal, June 30, 2018 A3.

Maybe that’s why the police got there in under a minute.

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Filed under Controls, Corporation, Directors, Duty, Duty of Care, Governance, Government, Internal controls, Oversight, Third parties, To report

Compliance incentives

“CFPB Decides Not to Fine Citi on Overcharges,” The Wall Street Journal, June 30, 2018 B12.  Company failed to lower credit card interest rates for some customers when it should have.  It will refund the overcharges and fix its practices, but won’t pay a fine.

Citi self-reported, and proposed full restitution.

Would this have happened under the prior Director at the CFPB?  Or would the offense have led to a large fine as well?  To what purpose?

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Filed under Accuracy, Communications, Compliance, Compliance (General), Controls, Corporation, Duty, Duty of Care, Governance, Internal controls, Oversight, To report

Conflicts as information

“McKinsey Held Back Chapter 11 Positions,” The Wall Street Journal, June 20, 2018 B1. Consultant advises in bankruptcy proceedings while holding undisclosed interests in the outcomes.

Did McKinsey not know that they had these investments?  Did they not have a process for checking for conflicts?  Or did they not care?  Did the lawyers not ask when employing an agent?  Was there no policy, at McKinsey or the court or the attorneys, about conflicts?

Maybe they need an outside consultant to review their processes.  Lots of really cool slides.

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Filed under Access, Accuracy, Compliance, Compliance (General), Controls, Corporation, Definition, Duty, Duty of Care, Governance, Information, Internal controls, Lawyers, Oversight, Third parties, To report

It’s not just VW

Often, a corporation’s violation of law don’t result in a conviction of the senior officers or directors.  Sometimes it does, and when it does, that’s a powerful compliance message.

“Audi CEO Is Arrested In Emissions Scandal,” The Wall Street Journal, June 19, 2018 A1. Executive jailed in Germany to prevent obstruction of ongoing investigation into emissions testing scandal at VW.

This goes to Governance, Compliance, and Information.

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Filed under Compliance, Compliance (General), Controls, Corporation, Culture, Directors, Duty, Employees, Governance, Oversight, To report, Who is in charge?

Details matter

“New Math: Firms Repair CEO Pay Flubs,” The Wall Street Journal, May 31, 2018 B4. Lots of mistakes being made in disclosure about how much money the CEO really makes.

Curious as to why all the mistakes are reports that are too low rather than too high?  Except for Warren Buffett, who gets paid $100,000 a year, but also gets ~$400,000 in security services at his home, where he works a lot.

What does it say when the even the company doesn’t know what the CEO gets paid?  Isn’t this information that they should manage a bit better?

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Filed under Accuracy, Communications, Compliance (General), Controls, Corporation, Data quality, Duty, Governance, Internal controls, Oversight, To report

Sniff test

What happens to compliance when the CEO and her boyfriend collaborate to create a culture of secrecy and fear?

“Partners in Blood,” The Wall Street Journal, May 19, 2018 C1.  Reports from the trenches at Theranos, which said it was able to run a range of tests from a few drops of blood; it couldn’t.  SEC charges company with fraud, and investors lose millions.

While the implications of a relationship of the CEO goes to Governance, are there also links to Compliance and Information?  What impact did the culture have on the company’s compliance?  How do investors know about the nature of a CEO’s personal relationships leaking into the corporate environment?

Who should have seen this and reported it to someone?  Why didn’t the directors smell a rat?

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Filed under Board, Compliance, Culture, Culture, Directors, Duty, Employees, Governance, Oversight, Oversight, Risk, Supervision, To report