In this piece, Gerry Caron, Chief Counsel, Safety, Health & Environmental at Cabot Corp., a Boston-based specialty chemicals company, pulls lessons from the wreckage of three compliance disasters: the misdeeds of former Theranos CEO Elizabeth Holmes; Boeing’s 737 Max debacle; and VW's loony campaign to evade emission standards. All three cases triggered the same “tone-at-the-top” factor cited in the US Department of Justice criminal division’s guidelines for the evaluation of corporate compliance programs. "The emphatic pronouncement from on high (the C-suite) of an ambitious corporate mission, which excluded any ongoing conversation, learning, or feedback during execution, seemingly was the Achilles heel in all three cases,” Caron says. “Compliance culture is critical to the mission of every organization — and an essential part of the in-house practice."
Check out What the Theranos, Boeing, and Volkswagen Compliance Lapses Have in Common at ACC Docket.
Source: ACC Docket
Published August 5, 2022.
