Six Do’s and Don’ts for Due Diligence Questionnaires

Six Do’s and Don’ts for Due Diligence Questionnaires

“Wait, they want three months of the CEO’s personal bank statements?  Are they insane?”  This was a real request to one of my clients via a due diligence questionnaire.  When I called to inquire with the requesting company why they needed this, they said that they wanted to ensure that the CEO wasn’t receiving “unusual payments” that could be a bribe. 

Due diligence questionnaires are a critical tool for understanding third-parties.  But they can quickly get out of control, putting unreasonable burdens on the answering party, and at worst, invading the privacy of individuals in wholly unnecessary ways. 

How do you balance the legitimate need for information with the reality that no questionnaire can fully protect the company from the possibility that the third-party will misbehave?  Here are three do’s and don’ts when it comes to due diligence questionnaires.

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Speak Now, and Never Hold Your Peace

Speak Now, and Never Hold Your Peace

How many times have you been in a meeting where the boss asks, “Does anyone have any ideas about how to (insert goal here)?” followed by silence.  Co-workers look at each other, no one wanting to pipe up in case their idea is badly received or laughed at by others.  Finally, the boss looks exasperated and either answers the question herself or calls on someone to answer.  What should you do if you find yourself in this situation?  Speak up, speak first, and speak with authority.

In 2009 a study was conducted at the University of California, Berkley where groups of four men and four women were asked to work together to complete a complex math problem.  No one was assigned the role of leader.  The discussion between the group members was videotaped.  Later, a panel of viewers who did not know the people solving a math problem watched the video and were asked, “Who is the leader of the group?”  Astonishingly, all panelists agreed that the person who spoke first when discussing the math problem was the leader.  Not only that, 94% of the final answers turned in by the groups were originally proposed by the person who spoke first.  

Researchers concluded from this experiment that not only did group members perceive the person who spoke first as the leader, but outside observers watching the interaction perceived the first person to speak as the leader too. 

How do you use this research to improve your leadership? 

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Celebrating Spark Compliance's Two-Year Anniversary!

Celebrating Spark Compliance's Two-Year Anniversary!

I am absolutely thrilled to say that last week my company Spark Compliance Consulting reached its milestone two-year anniversary!  When I started Spark Compliance on Feb. 1, 2016, I had no idea that we would grow so rapidly and have the opportunity to work with such fantastic multi-national clients. 

We’ve recently opened our Atlanta office, with Ramsey Kazem heading the charge for our Eastern and Southern clients, while Diana Trevley continues to run all of our U.S. operations from Los Angeles.  We feel so lucky to have been working with you and we want to thank you for your support.

We’re also extremely pleased to announce that for the second year running, we’ve been nominated as Compliance Consulting Team of the Year at the International Women in Compliance Awards.  I’ve also been nominated for the inaugural Mentor Award for Advancement of Women in Compliance. Many of our award-nominated clients will be joining us at our table at the black-tie gala will be held March 22 in London. (our press release is HERE).

I couldn't be more grateful for my business or for the compliance community!

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Making Your U.S Policies or Code of Conduct Global? Avoid These Seven Mistakes!

Making Your U.S Policies or Code of Conduct Global?  Avoid These Seven Mistakes!

It seems so simple – just roll-out your U.S. Code of Conduct or policies to the rest of the world.  They’re already written, right?  And you’ve had a lawyer look them over in the States.  What could be easier?  Hold on right there.  It’s not always obvious that certain words, phrases or concepts may need to be changed or removed in order to meet with the expectations of your employees in the rest of the world.  Here are the top seven things to avoid in globalizing your Code, employee handbook or policies...

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Creative Places to Advertise your Whistle-Blower Hotline

Creative Places to Advertise your Whistle-Blower Hotline

A couple of weeks ago my Wildly Effective Compliance Officer Tip of the Week was about creative places to put your whistle-blower hotline.  Since that day, I’ve received several notes about creative places to put the whistle-blower hotline to advertise it.  If your hotline number is only on a poster in the break-room, why not try one of the following to spice things up?

Mobile Phone Stand

The clever folks at Balfour Beatty had a problem.  Huge numbers of their workforce never come to an office.  In fact, most of them work on construction sites all day.  Keely Hibbit, Group Head of Business Integrity, and her team sourced a mobile phone stand with the whistle-blower hotline number on it.  The stand lays flat on the back of a cell phone, then clicks open to hold the phone up (like a snap bracelet for any of you alive in the 90’s)…

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