Who needs a Code of Conduct? Both private and public companies are required to have a code of business ethics and conduct. The Code is not legal advice and is not to be used as an employee manual of instructions. The ethics standards are provided to encourage a compliant corporate culture and to point the employees in the right direction to receive support. Because it is impossible to detail each and every possible situation in the course of business, the [...]
Xcelus provides custom compliance courses which means the training is created and developed for the specific client needs and will be solely owned by our client. Custom also enables us predict and control the costs of the training courses. For example, for the certification of Conflict of Interest we may decide to do a high cost graphic animation video and control the cost by making it as short as 2 minutes. Or we may reduce development costs with an online certification [...]
As the Department of Justice and the Securities Exchange Commission increase investigations of FCPA violations, companies try to determine the best way to prevent bribery. How about asking the enforcers of the FCPA? Bill Jacobson is a former assistant chief of the Criminal Division Fraud Section of the DOJ. He was a leader of the FCPA investigation teams and elevated violations to prosecution. Jacobson advised five elements to avoid prosecution: Self Reporting In the instance of a scandal, it is [...]
Guilty. Garth Peterson, a former real estate investment managing director for Morgan Stanley was sentenced to nine months in prison on August 16th, 2012 for violations of the anti-bribery laws under the U.S. Foreign Corrupt Practices Act (FCPA). Peterson plead guilty to conspiring to evade internal accounting controls which were maintained by his former employer, Morgan Stanley. Bribery. Prosecutors accused Peterson of enabling a Chinese government official and a Canadian lawyer to secretly buy a valuable Morgan Stanley property in [...]
One employee. The trial of former UBS employee, Kweku Adoboli begins in London today, providing another example of how a violation of one employee has the potential to impact an entire company. The trial is expected to last eight weeks with the potential to expose the UBS company culture and business practices. Both current and former employees will testify as the company is expected to be scrutinized. UBS is not on trial and will not be able to respond to [...]
Xcelus will be presenting October 25th during the Sponsored Lunch & Learn Sessions. Presentation Details: Your Audience Has Changed… Shouldn't Your Training Change as Well? Join Xcelus for a walk down memory lane to see how the labor market has changed and how learning technology has evolved. By 2020, 50% of the labor force will be from Generation Y. Training which worked in the past may not meet the attention span or the expectations of the new labor force. From the chalkboard [...]
Avoid FCPA Investigations. Many companies ask what can be done to avoid the increasing long arm of the U.S. law enforcers who are vigorously pursuing violations of the FCPA. The short answer: train employees to eliminate corruption. The long answer: set up an effective legal framework aimed to combat corruption with comprehensive policies and procedures to address the risk of corruption; and continuously nurture a corporate culture with zero tolerance of corruption from the top executives to individual employees [...]
The basis for the A&E television show The First 48 is an excellent metaphor for creating videos for training. The short description for the popular television show is as follows: “For homicide detectives, the clock starts ticking the moment they are called. Their chance of solving a case is cut in half if they don't get a lead in THE FIRST 48™. Each passing hour gives suspects more time to flee, witnesses more time to forget what they saw, [...]
Yes! Compliance training is absolutely necessary. In the midst of violations of the Foreign Corrupt Practices Act (FCPA), both the U.S. Department of Justice and the Securities and Exchange Commission determined not to pursue charges against Morgan Stanley because of the company’s robust compliance program. Allegations of fraud were committed by one of Morgan Stanley’s managing directors, Garth Peterson. According to the SEC complaint filed in April, 2012, Peterson evaded the company’s internal controls when he convinced Morgan Stanley to sell [...]
Xcelus has received the 2012 Silver Stevie Award for their Code of Conduct training video. Xcelus was recognized for its creativity and production quality. The training video developed by Xcelus was part of Life Technologies annual code of conduct employee training. “It is a great honor to be recognized for excellence for our training development”, said Todd R. Corbett, President and founder of Xcelus, LLC. Xcelus’ services for this project included instructional design, script development, storyboard development, video motion [...]
