Category Archives: Culture


Labels are shorthand.  Does the person using the label mean the same thing as you do?

“For Some Bonds, It’s Too Easy Being Green,” The Wall Street Journal, August 20, 2018 B1.  A quarter of Chinese bonds marketed as green bonds were rejected by “a de facto watchdog for the market” as not really being environmentally friendly.

On the Internet, no one knows you’re a dog.  In the world of finance, who validates your dogness?  What does it say about a company that tells fibs about the greenness of their bonds?

Are labels inherently suspect?  Or inherently believable?


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Filed under Accuracy, Communications, Controls, Culture, Definition, Governance, Information, Internal controls, Third parties


The value of information can be calculated in multiple ways, from multiple viewpoints.

“My Boss Makes What? (Employees Work Harder If They Know),” The Wall Street Journal, August 6, 2018 R1. Salary transparency makes people work harder.

Is what you make “private”?  Should it be?  Whose interests are served by keeping this information private?  Who owns it, you or your employer?  Do anyone have a duty to keep this private?  Why would your employer want this kept quiet?  To avoid Sally complaining that she works harder/better/faster/quieter than Sue, and should be paid more? Or to keep a competitor enticing Sally away?

Ask yourself why you want to keep your salary private.  Sure, you don’t want marketing agencies targeting you because you’re wealthy, but they probably can approximate your salary anyway.

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Filed under Access, Accuracy, Communications, Controls, Corporation, Culture, Duty, Employees, Governance, Information, Internal controls, Managers, Ownership, Privacy, Third parties, Value

How much due process is due?

“CBS to Weigh CEO’s Fate,” The Wall Street Journal, July 30, 2018 A1.  Discussion over whether CEO accused of sexual harassment should stand down while the investigation continues.

Curious that Urban Meyer has to stand aside while an investigation into whether he should have reported domestic abuse by an assistant coach 9 years earlier at a different school, but Leslie Moonves remains on board as the CEO of CBS.  See

What does it say about a company’s culture when, in the current environment, the CEO can remain in his job during such an investigation?  How convinced are the rank-and-file employees that the sexual harassment policy is real, or just a piece of paper?  Are the directors serious about this policy?  What about other policies?

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Filed under Board, Compliance, Compliance, Compliance (General), Corporation, Culture, Culture, Directors, Duty, Employees, Governance, Oversight, Oversight, Policy

Churn ’em, Burn ’em, and Learn ’em

More of the same old stuff.

“Advisers Blew Whistle on Wells Fargo Wealth Unit,” The Wall Street Journal, July 28 2018 B1.  Sales incentives drive improper behavior at Wells Fargo.  Again.

The good news is that four Wells Fargo financial advisers tipped off the DOJ and the SEC to what was happening.  High-wealth investors were steered to investments that would result in higher fees paid to Wells Fargo.

So the culture wasn’t entirely corrupt.  There’s hope.

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Filed under Compliance, Compliance (General), Controls, Corporation, Culture, Duty, Employees, Governance, Internal controls, Investor relations, Policy, To report

Higher learning

Sometimes, I select stories just for the headline I can write over it.

“Temple Is Probed Over Online MBA Marketing,” The Wall Street Journal, July 26, 2018 B5. University accused of deceptive marketing to prospective MBA students.

What is the lesson here?  School may have tweaked some test data to improve the school’s ranking.  Did non-students learn more than students?

Dean lost his job.  The school’s reputation takes a hit.  US News & World Report it told the school can’t verify its information.  Maybe the ex-Dean can be the subject of a case study in the Ethics curriculum.  Or a Compliance course, if the school has one.

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Filed under Accuracy, Compliance, Compliance (General), Controls, Culture, Data quality, Duty, Employees, Governance, Information, Internal controls, To report


Apparently, law firms don’t do background checks on incoming partners, at least not if they’re big money makers.

“Top Lawyers Evade Harassment Claims,” The Wall Street Journal, July 31, 2018 A1.  Partner switches to a new firm that didn’t know of his history of harassment.

See also a posting last month on a related topic:

Do law firms think they are somehow immune from the laws that apply to their clients?  Do they read the news?  Do they have a fundamentally different culture?

Just asking.  But this does go to both Compliance and Governance.



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Filed under Controls, Culture, Duty, Governance, Internal controls, Lawyers, Third parties, To report

Caesar’s Wife

One of the common law duties of all employees is to report material departures from the company’s Code of Conduct.  Interesting when that’s applied to a super star.  Over something that happened nine years ago, at a different school.

“Ohio State Puts Meyer On Leave Amid Probe,” The Wall Street Journal, August 2, 2018 A6.  Coach put on admin leave pending investigation into whether he knew that one of his assistant coaches beat up his spouse in 2009, when the coaches were both at Florida.

It was not alleged that Coach Meyer knew of the abuse, but that his wife did.  But Coach Meyer said he’d learned of the abuse before his wife did, and he and his wife counseled the offender and his wife at the time.

How could Coach Meyer have purged himself of this taint?


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Filed under Culture, Duty, Employees, Governance, To report