becoming a more effective ethics and compliance …...1 becoming a more effective ethics and...

1

Becoming a More Effective Ethics

and Compliance Officer

Society of Corporate Compliance & Ethics

September 13, 2009

Daniel R. Roach, JD

VP Compliance & AuditCatholic Healthcare West

Joseph E. Murphy, CCEP,

JD Of Counsel, CSLGSenior Advisor, Integrity Interactive

Ann Oglanian, JD President and CEORegroup, LLC

A Workshop in Three Parts:

�How to take charge of your career - it starts with you

�Empowerment, Independence and a Seat at the Table

�Professional Development: 5 Key Skills

2

2

HOW TO TAKE CHARGE OF YOUR CAREER - IT STARTS WITH YOU

PART I

Daniel R. Roach, JD

VP Compliance & Audit

Catholic Healthcare West

What is an effective ethics & compliance program?

� Who defines?

� How is it measured?

4

3

Impediments to Effectiveness

� Personal

•

•

•

•

•

5

� Organizational

•

•

•

•

•

Overcoming Personal Impediments

�

�

�

�

�

6

4

Overcoming Organizational Impediments

�

�

�

�

�

7

Attachments

� Federal Sentencing Guidelines on Effective

Compliance & Ethics Programs

� Sample compliance metrics

8

5

Resources

� Why It’s Hard to Be Good , Al Gini, Rutledge 2006

� The Lucifer Effect: Understanding How Good People Turn Evil, Philip Zimbardo, Random House 2008

� The Seven Signs of Ethical Collapse: How to Spot Moral Meltdowns in Companies . . . Before It’s Too Late, Marianne M. Jennings, J.D., St. Martin's Press 2006

� How to Pad Your Expense Report . . . And Get Away with It,Employee X, Easy Money Press 2005

� Crucial Conversations: Tools for Talking When Stakes are High, Kerry Patterson et. al., McGraw-Hill, 2002

� Difficult Conversations: How to Discuss What Matters Most,

Douglas Stone et. al., Penguin Books 1999

9

Resources

� 2004 Federal Sentencing Guidelines,

Organizations. Chapter 8 – Part B. Remedying

Harm from Criminal Conduct, and Effective

Compliance And Ethics Programs.

http://www.ussc.gov/orguide.htm

� Building a Career in Compliance and Ethics.

Joseph E. Murphy, Joshua H. Leet, Society of

Corporate Compliance and Ethics, 2007.

10

6

EMPOWERMENT, INDEPENDENCE AND A SEAT AT THE

TABLE

Joe Murphy, CCEP

Of Counsel

Compliance Systems Legal Group

PART II

11

What Counts in a Compliance and Ethics Program?

� Greatest Risk = Senior Executives

� Most Direct Tool to Reach Them?

• Another Senior Executive – The Chief Ethics &

Compliance Officer (“CECO”)

� To be effective, the CECO needs the power and

resources to get things done

12

7

What Counts in a Compliance and Ethics Program?

� CECO as a leading

indicator

� Is the CECO:

• Independent?

• Connected?

• Empowered?

• Professional?

� Indicators:

• Listed in the Annual Report

• Background, expertise, CCEP

• Reports to Board

• Can be terminated only by Board

• Not in the legal department

• No carve outs from the program

13

Power and Resources to Get Things Done

� A CECO’s skills, experience and character are

essential, but…

� What are the conditions that help enable effective

performance?

14

8

CECO – Empowered from the Top

� Board resolution

• Have the board adopt a resolution establishing and empowering the compliance and ethics program.

• Publish the board’s compliance resolution in the

company’s annual report/proxy statement.

See Singer, “AEP’s Ethics Interviews Are ‘About the Passion of the People,’” ethikos 13 no. 6

(May/June 2000): 1, 3; See Murphy, “Chapter 10: Protections for Compliance People,” in Murphy & Leet, Working for

Integrity (Minneapolis: Society of Corporate Compliance and Ethics, 2006): 397-416.

15

CECO – Empowered from the Top

� CO appointed by Board

• Have the compliance officer appointed by the board,

as part of a board resolution.

See Murphy, “Compliance Officers: One Part Ombudsman, Two Parts Watchdog,” National

Law Journal (Dec. 14, 1992): S2.

16

9

CECO – A Key Player

� CO in key meetings

•The board can specify that the compliance

officer shall participate in all executive meetings,

including strategic, operational and review

meetings of the CEO’s executive management

team, and has input into significant business

decisions.

See Petry, “Assessing Corporate Culture: Part II,” ethikos 19 no. 1 (July/Aug. 2005): 10, 13.

17

Empowerment Through Security

� Empowerment

• One element of the compliance professional’s

empowerment is having sufficient security to act from a position of strength.

• Provide compliance professionals with indemnification, insurance, and a severance package.

See Murphy, “Chapter 10: Protections for Compliance People,” in Murphy & Leet, Working for

Integrity (Minneapolis: Society of Corporate Compliance and Ethics, 2006): 397-416; Murphy, “Questions to Ask About an In-House Compliance and Ethics Job offer,” ethikos 18 no.

3 (Nov./Dec. 2004): 7, 9.)

18

10

Empowering the CECO – in any Entity

� Employment contract

• Have an employment contract for the compliance officer.

See Murphy, “Enhancing the Compliance Officer’s Authority: Preparing an Employment

Contract,” ethikos 11 no.5 (May/June 1998): 5.)

19

Board Control

� Board control

• Have all decisions affecting the compliance officer’s

employment by the company, including:

�Hiring, transfer, termination and similar matters

�Any decision limiting the scope of the program

• Require the prior approval of the board.



20

11

Unfiltered Audit Committee Access

� CO audit committee access

• Provide the compliance officer with unrestricted access to the audit committee in executive session.

See Kaplan, “The Boss’s New Job: Ensuring Compliance Program Effectiveness,” ethikos 18

no. 6 (May/June, 2005): 1, 3.

21

Mandatory Board Reports

� Mandatory board reports

• Have mandatory reporting by the compliance officer

to the board on key points, including any allegations about senior officers or rejection of the compliance

officer’s advice.

See Singer, “An Ethics Officer of Olympian Proportions,” ethikos 18 no. 2 (Sept./Oct. 2004): 6,

8.

22

12

Mandatory Escalation

� Escalation guidelines

• Establish and publicize guidelines throughout the company, describing the types of allegations that must be centrally reported to the chief compliance

officer, so that this officer can ensure appropriate matters are reported to the board.

23

Instant Knowledge for your Board

� Compliance officer on board

• Have the board recruit a compliance officer from

another company to be a board member.

See Murphy & Roach, “Compliance Officer on Board: What Your Audit Committee is Missing,”

ethikos 20 no. 3 (Nov/Dec 2006): 12.

24

13

Sending a Message

� Take your CO to lunch

• Something as simple as taking the compliance officer to lunch can help empower the compliance officer.

• A board member could do this to enhance

communications; the CEO could do this, especially in the company cafeteria, to send a message of support for the program.

25

Empowerment Through Professional Standards

� C&E professional ethics

• Have the company formally agree to abide by the

professional ethical standards applicable to its compliance and ethics staff, i.e., the SCCE Code of

Ethics.

• This goal could be reached by such means as inclusion in employment contracts, a board of directors’ resolution, or inclusion in position descriptions.

See SCCE Code of Ethics, (Minneapolis: Society of Corporate Compliance and Ethics, 2007),

http://www.corporatecompliance.org/Content/NavigationMenu/Resources/ProfessionalCode/SCCECodeofEthics.pdfMurphy, “Chapter 10: Protections for Compliance People,” in Murphy & Leet, Working for Integrity: Finding the Perfect Job in the Rapidly-Growing Compliance and Ethics Field (Minneapolis: Society of Corporate Compliance and Ethics, 2006): 397-416.

26

14

Outside Advice for the CECO

� Outside professional services

• Give the compliance officer full authority to retain professional services, including legal counsel, to assist in carrying out the program.

• This could be set out in the board resolution establishing the program.

27

Keeping Legal on Your Side

� Compliance program lawyer

• Have a senior-level lawyer designated as the lawyer

for the compliance program, to develop expertise in the compliance and ethics area and provide support

to the compliance officer.



28

15

Making Sure Things Get Done

� Assistant compliance officer

• Have a second in command for the program, to handle administrative matters and act in the compliance officer’s absence.

• This is especially important if the compliance officer has other responsibilities besides compliance and ethics.

See Petry, “EOA Survey: Companies Seeking to Integrate Ethics Through the Whole

Organization,” ethikos 15 no. 1 (July/Aug. 2001): 1-2.

29

Getting Buy-In

� Interdepartmental compliance committee

• Have an interdepartmental compliance committee,

including members from key departments (e.g., HR, legal, internal audit, IT, etc.) and from the business

units, with sufficient authority to make commitments for their departments/units.

See Scarpino, “NCR Corporation’s Four-fold Ethics & Compliance Model,” ethikos 20 no. 1

(July/Aug. 2006): 7-8; Jordan & Murphy, “Compliance Programs: What the Government Really Wants,” ACCA Docket (July/Aug. 1996):10, 15-16;

Kaplan, “The Boss’s New Job: Ensuring Compliance Program Effectiveness,” ethikos 18 no. 6

(May/June, 2005): 1, 3; HHS, “OIG Compliance Program Guidance for Pharmaceutical

Manufacturers,” Federal Register 68,(May 5, 2003): 23,731, 23,740, 23,743.)

30

16

Getting the Committee to Meet

� Committee meeting schedules

• Have the interdepartmental compliance committee schedule its meetings prior to the audit committee’s meetings.

• The compliance committee then feeds into the compliance officer’s report to the audit committee.

• This helps avoid postponing the compliance committee’s meetings, and can enhance attendance.

31

Keeping in Touch with the Field

� Field participation

• Invite field managers to participate in compliance

committee meetings to bring fresh perspectives, and to spread understanding about the compliance and

ethics program.

32

17

Getting the Program into the Field

� Business unit C&E officials

• Have compliance officials designated in all subsidiaries and business units.

See Murphy, “Facility Compliance Coordinator Position Could Help Ensure That Compliance

Program Reaches the Field,” Prevention of Corporate Liability Current Report 4 (Dec. 16, 1996): 12;

Scarpino, “NCR Corporation’s Four-Fold Ethics & Compliance Model,” ethikos 20 no. 1

(July/Aug. 2006): 7, 9.

33

Really Getting the Program into the Field

� Facility compliance and ethics officials

• Require a compliance and ethics person be assigned

for each substantial company physical facility.

• This model is prevalent in safety programs.

See Jordan & Murphy, “Compliance Programs: What the Government Really Wants,” ACCA

Docket (July/Aug. 1996): 10, 15; In re Grumman Corp., settlement agreement (E.D.N.Y., Nov. 23, 1993).

34

18

Giving the Field Person Clout

� CO authority over remote compliance officials

• Give the compliance and ethics officer at least some level of authority over the business unit compliance officials, such as control over their removal, and input

into their evaluations.

35

Guidance for the Field

� Business unit program manual

• Have a compliance program manual for guidance for

the compliance and ethics people in all business units and risk areas.

• It can explain how to do each of the compliance functions, e.g., training, distributing the code, self-assessments, etc., and provide other resources such as contact names and numbers.

See Sigler & Murphy, Interactive Corporate Compliance: An Alternative to Regulatory

Compulsion (Westport, CT: Quorum Books, 1988): 85.

36

19

“Incentives” for Laggards

� “Invitations” to visit the board

• If a business unit is lagging in its compliance and ethics efforts, have the board’s audit or compliance committee “invite” the unit’s senior manager to

discuss the unit’s compliance and ethics program’s progress.

See Singer, “Marsh’s Business Reforms: Much Ground Covered in Little Time,” ethikos 19 no. 6

(May/June 2006): 1, 3-4.

37

Covering Risk Areas

� SMEs

• Have experts in each risk area assigned as the

subject matter experts (SMEs) for those areas, e.g., antitrust, privacy, money-laundering, etc.

• The SMEs would work with the compliance officer and ensure that their areas are appropriately covered by compliance efforts.

See Singer, “Exelon Excels at Reaching Out,” ethikos 16 no. 6 (May/June 2003): 7.

38

20

Executive Role in Risk Areas

� Responsible executives

• Have a senior manager responsible for each compliance risk area; this person would be the executive responsible for ensuring that the

compliance work in that risk area was effective.

• The executive would not necessarily be the risk area subject-matter expert.

See Kaplan, “Sundstrand’s ‘Responsible Executive’ Program,” Corporate Conduct Quarterly

(now ethikos) 4 (1996): 33.

39

Risk Area Plans

� SME plans

• Require an annual plan for compliance efforts in each

compliance risk area, e.g., export control, EEO, antitrust, etc.

• If there are responsible executives or other subject matter experts, they would be responsible for preparing the plans.

40

21

Increasing Risk Area Focus

� SMEs reporting to board

• Have each of the different compliance risk area subject matter experts and/or responsible executives report occasionally to the board/board committee on

their portion of the compliance and ethics program.

41

Guidance for all the C&E People

� Workshops for C&E professionals

•Provide seminars and workshops for

compliance and ethics people throughout the

company, including those in the business units

and those involved in the risk areas.

•These can cover the “how to” of compliance and

ethics work, and the various compliance risk

areas.

See Singer, “Needed from Bertelsmann’s Ethics & Compliance Officer: A ‘Diplomatic Effort,’”

ethikos 17 no. 2 (Sept./Oct. 2003): 7, 9.

42

22

Guidance for all the C&E People

� Sales skills

•Train all compliance and ethics managers on

effective communications and sales skills, to

help them in promoting the program.

See “Chapter 10: Selling Compliance (and the Importance of Your Job) to Management,” in

Murphy & Leet, Building a Career in Compliance and Ethics (Minneapolis: Society of Corporate Compliance and Ethics, 2007): 145-57.

43

A Reminder for Everyone

� Responsibility for compliance

• Specify in the code, corporate policy or other

important and widely-read document, that responsibility for actual compliance and ethical

conduct is squarely on the shoulders of each employee, and especially managers, and not the compliance and ethics officer

See US Sentencing Guidelines, Section 8B2.1 (b)(2)(B).

44

23

Resources

� Ethics Resource Center, SCCE, et al., Leading Corporate Integrity:

Defining the Role of the Chief Ethics and Compliance Officer(August 2007)

http://www.corporatecompliance.org/Content/NavigationMenu/Resources/Surveys/CECO_Definition_8-13-072.pdf.

� Code of Professional Ethics for Compliance and Ethics

Professionals (SCCE) http://www.corporatecompliance.org/Content/NavigationMenu/Resources/ProfessionalCode/SCCECodeOfEthics_English.pdf

� Murphy, 501 Ideas for Your Compliance and Ethics Program: Lessons from 30 Years of Practice 11-26 (SCCE; 2008)

45

PROFESSIONAL DEVELOPMENT: 5 KEY SKILLS

Ann Oglanian, JD

President and CEO

ReGroup, LLC

PART III

46

24

Here’s the idea:

� Your role is evolving…fast

� The skills necessary to be a successful are

evolving at the same pace

� Understanding the rules is necessary for

success…however, it’s not enough

� You need to develop the both the core business

skills and the personal attributes to effectively

administer a compliance program

� Today: introduction to five key business skills

47©ReGroup, LLC 2009

The Toolkit

� Why and how to define your job

� What does success look like?

� What does it mean to become an effective

compliance professional?

� Top 5 skill sets


25

Success is Linked


An Effective Compliance Professional

50

What is expected?

©ReGroup, LLC 2009

26

According to Whom?


Workshop: Skills Sets

+1.

2.

3.

4.

5.

-1.

2.

3.

4.

5.


27

Expectations for Compliance Professionals: Evolving

� Strategic and Tactical

� Higher Profile

� Management/Delegation

� Communication

� Business Analysis and Insight

� Effective Use of Technology

� Risk Assessment and Analytics

� Ethics Management

� Manage dilemma: The Opposable Mind

� Tell the Truth


Beyond the Rules…The Rest of the Story

1. Understanding existing and emerging issues; learning new information

2. Designing solutions to technical problems

3. Integrating systems and functions

4. Understanding business practices, approaches, organization, politics, and culture

5. Managing projects; planning, prioritizing, and administering work

6. Communicating and listening; gathering information

7. Focusing on results

8. Thinking strategically

9. Influencing and persuading

10. Being adaptable


28

� Hard skills: assumed

• Know the rules, write policies and procedures, training, sanctioning, ethics, identify conflicts of interest, assess risk…

� Soft skills make the difference

• #1 Skill = Communication

�Verbal

�Written

The Market’s View: CCO Recruiters


CEO Questions

� What is your mission?

� How well do you handle people?

� How well do you know the business?

� Can you tell me how you measure success?

� Are we doing a good job?

� How much is enough?


29

Attitude:

THE MIND-SET OF THE TRUSTED PROFESSIONAL

1. Professionals have a bias for results.

2. Professionals don’t just try...they’re invested!

3. Professionals realize (and act like) they’re part of something bigger than themselves.

4. Professionals have standards that transcend organizational ones.

5. Professionals know personal integrity is all they’ve got.

6. Professionals aspire to be masters of their emotions; not be enslaved by them.

7. Professionals aspire to reveal value in others.

8. Professionals continue to learn throughout their careers.

57

© Wiersma & Associates

Become a Trusted Adviser

� You must win trust of clients, managers, board

members, peers and regulators. Steps to building

trust:

Transparent: Open, going beyond current requirements

or expectations

Responsible: Clearly acting in the broader and longer

term interests of all

Uncompromising: Committed to highest ethical position

Successful: Results-driven

Temperate: Structured and executed against risks,

avoiding reactionary decisions


30

Professional Development: The Premise

� Technical skills, while essential, are a minimum.

� How you conduct yourself defines whether you’re

considered by others to be a trusted professional.

� Bottom Line:

59

Technical skills get you in the game.

Conducting yourself professionally leverages your chances of winning.

©ReGroup, LLC 2009

60

Skill #1 = Communication

©ReGroup, LLC 2009

31

How NOT To Communicate

� It’s easy to misinterpret communication issues as

indifference or a disregarding attitude.

� Sets up downward spiral toward complete

communications failure.

� We sabotage our own attempts to communicate.

� You have to OWN your communication.


� Failing to listen

� Being dismissive

� Inappropriate nonverbal communication

� Giving too much information

� Lack of documentation

� Not providing training

� Losing patience

� Failure to inform

� Showing off

� Lying

62

Top 10: The Deadly Sins of Miscommunication

©ReGroup, LLC 2009

32

Just Say No?

� The ‘because the [name a regulator] said so’

approach to winning friends and influencing people

• How’s that working for you?

• Good compliance is good business – believe it and be able to talk about it.


How to Say NO, without saying NO

� You’re often in a position to be the bearer of bad

news

• Worse yet, your delivery can be demoralizing

• And have a negative impact on the firm’s profits

� Consider a new delivery…

64

33


� The ReGroup RED Rule of 3

• Always say 3 things

�Not 4…never, ever. More is not better.

�It takes practice

• Keep it Real

• Seek to Educate

• Demonstrate your idea

How to Talk CEO

©ReGroup, LLC 2009 66

34

Make Your Ideas Sticky

� Compliance ideas are not naturally sticky…or

interesting…

� Sticky = effective

� The curse of too much knowledge

� Ever try humor?

� ReGroup Recommended Reading:

• Made to Stick, Chip Heath and Dan Heath


Made to Stick’s Six Principles of Stickiness

1. Simple

2. Unexpected

3. Concreteness

4. Credentialed

5. Emotional

6. Story

SUCCESs


36

Impact of Not Handling Conflict Well

� How not to:

• Nasty-gram

• Unnecessary escalation

• Run and hide

• Deer in the headlights

• Tears

� Results:

• They win

• You don’t


72

What are the Benefits of Handling Conflict like a Pro?

©ReGroup, LLC 2009

37

How to Handle Conflict Like A Pro

� Master your emotions

� Be respectful

� Own your own behavior

� DO right, not BE right

� Take pride in work well done

� Listen, listen, listen

� Ask more questions

� Seek areas of agreement first

� Neutralize your language

� In the heat of battle, ask yourself:

• “How would a professional handle this?”


Skill #3 = Speaking Truth to Power: An Ethical Dilemma


38

75

The truth that makes men free is for the most part the

truth which men prefer not to hear.

~Herbert Agar, A Time for Greatness (1942)

©ReGroup, LLC 2009

Speaking Truth to Power

� “Shooting the Messenger”

• Sophocles' play Antigone, 4th Century BC

• The King’s guards draw straws to choose the unlucky one who must tell his majesty the bad

news.

� Speaking truth to power is perhaps one of the

most difficult of ethical challenges because to

do so entails personal danger.


39

Clarify ethical dimensions of your firm and your CEO

� First question:

• Do you want me to tell you the truth?

• Are there any circumstances under which you do not want to hear the truth?

• Do you agree that when I tell the truth, I put myself at risk?

• Will telling you the truth make me more valuable to you?


Whose Truth?

� It is always the ‘truth’ as you see it:

• Be well prepared to support your version of the truth

• Understand and acknowledge where there are gaps in your truth

• Never bend the truth for your own purposes


40

Skill #4 = Building and Using Credibility


Required By Law

� The law gives the Compliance Program legitimacy

and relevance…

• The Compliance Program is the only risk

management function that is required by law.

� You give the Compliance Program credibility.


41

� A credible source of information makes for quicker and firmer decisions.

� A credible person is more likely to be heard and to have

his/her agenda approved and supported.

� Credibility is a cornerstone of effectiveness.

� Be assertive. Quickly and logically refuting counter-arguments - don’t get ruffled.

� Leverage the credibility of others.

• Highlight the credibility of your sources of information.

• Get introduced by a credible person.

� Learn the business

Why Build Credibility?

81

WHY?

HOW?

©ReGroup, LLC 2009

The Credibility Dilemma

� You’re required to have a robust point of view

issues that impact business prospects.

� When you take a clear position, you may be in the

position to have your credibility questioned or

undermined.

� In order to be effective, you must actively guard your personal credibility.


42

The Challenge

� Leadership is not a popularity contest.

� Accept the tensions between your job and the desires voiced by your peers.

� Actively guard your personal credibility.

� Only after your credibility is established can you manage change in your firm.

� Your credibility (and reputation) is all you have and you must take active steps to protect it.


Top 10 Ways to Kill Credibility

1. Whine

2. Allow criticism to go unanswered

3. Cheat or Lie

4. Believe everything your told

5. Shave corners (vs. critical thinking)

6. Provide answers based in “Because I/the SEC said so”

7. Fail to meet expectations – especially the ones you create

8. Be wrong. . . And then don’t correct the mistake

9. Being unable to explain who, what, where, when and how

10. Exaggerate


43

Set Higher Standards


Compliance Department Goals (example)

� The Compliance Department’s goal is to be viewed by

• Clients

• Colleagues, and

• Regulators as…


44

�Credible, knowledgeable and authoritative

�Controlled, measured and process-driven

�A value-added internal service provider

�Responsive, consultative and empowered

�A trusted adviser


Setting StandardsExpectations for Compliance Professionals

� Conduct compliance responsibilities in accordance with the highest ethical standards

� Demonstrate knowledge of the firm’s technical compliance requirements

� Know the role of the compliance department

� Demonstrate knowledge of the business

� Conduct compliance responsibilities in a consultative and professional manner


45

Setting StandardsExpectations for Compliance Professionals

� Be pro-active, inquisitive, able to exercise professional skepticism, and able think critically

� Contribute to the identification, assessment and mitigation of compliance risk

� Assist in the creation of policies and procedures to address the identified risks

� Properly and appropriately escalating compliance issues

� Participate as appropriate in industry efforts to develop and implement good compliance practices


90

There is nothing so useless as doing efficiently that

which should not be done at all.

~Peter F. Drucker

©ReGroup, LLC 2009

46

Skill #5 = Strategic Thinking


Overhead vs. Value-Added

� Assist in protecting the

firm’s reputation

� Design a compliance

program to meet

regulatory requirements

and improve internal

efficiencies

� Strengthen client

relationships; improve

sales and retention

92

� Create transparency by

packaging information in a

manner designed to enhance

decision-making

� Reduce regulatory and

business risks

� Improve individual

employees’ efficient

execution of their compliance

responsibilities

� Interact, transact and

integrate with vendors

©ReGroup, LLC 2009

47

Strategic Planning in Five Steps


SMART Plan

� Specific

� Measurable

� Accountable

� Realistic

� Time-Bounded


48

SUMMARY


Success is Linked


49

Check the Compass

� Know your skills and continue to learn

� Own your role…define it and communicate it

� Don’t ‘Just Say No”

� Manage conflict – don’t let it manage you

� Build and defend credibility

� Tell truth to power

� Set high standards for your own conduct

� When in doubt, ask yourself, “What would a professional do?”


98

Insanity: Doing the same thing over

and over again and expecting different results.

~Albert Einstein

©ReGroup, LLC 2009

50

Thank You!

99

Daniel R. Roach, JDVP Compliance & AuditCatholic Healthcare West

Joseph E. Murphy, CCEP, JD Of Counsel, CSLGSenior Advisor, Integrity Interactive

Ann Oglanian, JD President and CEORegroup, LLC

becoming a more effective ethics and compliance …...1 becoming a more effective ethics and...

Documents