Category Archives: Communications

Management of change

How do you make sure that your policies are keeping pace with law and society?

“Google Changes Harassment Rule,” The Wall Street Journal, November 9, 2018 B4.  Following an employee walkout over how the company handles/handled sexual harassment claims, Google will no longer require that such claims be subject to arbitration.

This ties to Governance (what rules do you have in place, and when do you update those), Compliance (how do you handle claims of policy violations), and Information (a claim is one type of information).

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Filed under Communications, Compliance, Compliance (General), Controls, Definition, Governance, Information, Oversight

Too much sharing

I’m a bit of a knowledge management wonk, having been involved in the then-nascent KM movement within the inhouse legal community in the early 2000s.  But there can be too much sharing.

“Sinclair Settles With U.S. on Ad-Sales Data,” The Wall Street Journal, November 8, 2018 B2.  A media group settles lawsuit over alleged sharing of information among television station owners, that may have led to higher advertising rates.

An interesting side note is that this all came to light when Sinclair proposed to buy another company and had to undergo a government investigation.

Are there restrictions on how much information can be shared between and among competitors?  Yes.  They are call “antitrust laws.”  And is there a risk of making a deal that subjects you to government scrutiny?  Yes.  The may discover all manner of minor and major sins.

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Filed under Access, Communications, Compliance, Compliance (General), Controls, Corporation, Discovery, Duty, Governance, Information, Internal controls, Knowledge Management, Oversight

Managing information

What does it say when you try too hard to “manage” the information that gets out?  Do you have the necessary “control” of that information?  When you try to “control” it, what does it say about you when the information gets out anyway?

This sounds like “the risk of selectively releasing information.”

“Turkey Slams Saudis Over Lack of Clarity About Slain Journalist’s Body,” The Wall Street Journal, November 1, 2018 A9.  Changing stories on the death of Jamal Khashoggi.

Apparently, there are international norms on what you need to say and how you need to say it, even if it information concerns events within a consulate.  Was disclosure legally required?  Maybe not, at least legally.  But when you do disclose, it’s a good idea to do so honestly.  Especially if someone else gets the information.

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Filed under Accuracy, Communications, Compliance, Controls, Culture, Duty, Governance, Government, Information, Internal controls, To report

Another one bites the dust

“Barnes & Noble Details CEO Firing,” The Wall Street Journal, October 31, 2018 B1.  CEO allegedly fired for sexual harassment and bullying, and interfering with the sale of B&N.

So, the CEO gets canned.  No severance package.  What message does this send to the rest of the organization (and, indeed, to other CEOs and other companies)?  How does the Board look on this one?  From a Compliance standpoint, and a Governance one, looks pretty good.

Might this be a pretext?  Could he have been fired for some other reason?

 

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Filed under Board, Communications, Compliance, Compliance, Compliance (General), Controls, Corporation, Duty, Employees, Governance, Internal controls, Oversight, Supervision

What’s worse than a tweet?

“FBI Probes Tesla Over Production Figures,” The Wall Street Journal, October 27, 2018 A1.  FBI conducts a criminal investigation into whether Tesla knowingly overstated anticipated production figures and thereby misled investors.

What if Tesla knew at the time that it couldn’t and wouldn’t meet the production targets it was then continuously providing the market?  When does mere puffery become criminal?  What controls would you need to have to prevent this at your company?

Do you have them?  Are they enforced?

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Filed under Accuracy, Collect, Communicate, Communications, Compliance, Compliance, Compliance (General), Controls, Corporation, Culture, Data quality, Duty, Duty of Care, Governance, Internal controls, Investor relations, Management, Oversight, To report

Management moves

No indication that this is Compliance-related; may just have been a personality conflict, or the continued shuffling of chairs under the new CEO.  But it certainly goes to Governance, which is at least tangentially related to information governance.

“Deutsche Bank Dismisses an Executive,” The Wall Street Journal, October 26, 2018 B10.  Bank dismisses its asset-management chief.

This may be just normal comings and goings.  But when a company dismisses/fires a member of its management board, it makes the news (probably has to be disclosed to the market especially since the guy handled the public offering of a major unit).  Especially when the company had fired its CEO earlier this year.

How is the rest of governance going there?  How’s the culture?  Is there a higher scrutiny of the bank this year?  On a whole host of issues?

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Filed under Communications, Culture, Governance, Investor relations

Conduct matters

“Uber’s Top Deal Maker Quits After Conduct Claims,” The Wall Street Journal, October 23, 2018 B3.  Senior executive (48) resigns after allegations of sexual misconduct.  Also alleged to have violated company policy with a consensual affair with a colleague.

See also https://infogovnuggets.com/2018/10/15/enforcement/ for an earlier nugget on this point.

So, a higher-up gets the heave-ho after bad conduct.  I guess the Compliance program has teeth.  But it did take a long time.  Firing (or moving aside) a high-producer shows a company’s commitment, even at a company with a bad history.  Did he get a package?  Multiple messages here.

 

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Filed under Communications, Compliance, Compliance (General), Controls, Duty, Employees, Governance, Oversight