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Will This One Stick?

Program on Compliance and Enforcement, New York University School of Law -

by Veronica Root

Over the past several years, there have been many attempts to garner greater transparency of the government’s use of nonprosecution agreements and monitorships.  On three occasions the party attempting to obtain a ruling that would reign in the government’s authority over these matters has won at the district court level.  In each of these instances, however, the court of appeals reversed.

In January 2011, a reporter filed suit as part of an attempt to obtain access to reports filed by a monitor who oversaw remediation activities at AIG.[1]  A D.C. district court, which had previously granted an order of confidentiality protecting the monitor’s reports, granted the reporter’s request for access to the reports.[2]  The district court “determined that: (1) the reports were judicial records; (2) the interests of the public weighed in favor of requiring disclosure of the reports; and (3) redacted Monitor Reports must be made available to the public.”[3]  The D.C. Circuit Court of Appeals reversed, finding that the reports were “not judicial records subject to the right of access because the district court made no decisions about them or that otherwise relied on them.”[4]

In 2015, a D.C. district court held that it had the power to “choose to accept or reject a deferred prosecution agreement pursuant to its supervisory powers.”[5]  The court rejected a deferred prosecution agreement, in part, because it failed “to require the appointment of an independent monitor to verify that the company remained in compliance with the terms of the deferred prosecution agreement.”[6]  On appeal, the D.C. Circuit concluded that the district court lacked authority to assess the advisability of certain terms included within the deferred prosecution agreement, including the decision on whether a monitorship was necessary.[7]

In 2016, a E.D.N.Y. district court concluded that it “had authority to approve or deny a deferred prosecution agreement and ordered the public release of the associated enforcement monitor’s reports.”[8]  The district court concluded that the monitor reports were judicial documents, making them subject to disclosure.[9]  The Second Circuit reversed, holding that “the Monitor’s Report is not a judicial document because it is not now relevant to the performance of the judicial function.”[10]  And like the D.C. Circuit, the Second Circuit maintained that the district court misunderstood its appropriate powers based on its supervisory authority.[11]

In these examples, district courts attempted to assert authority to supervise the government’s use of negotiated settlement agreements and the related monitorships that are often entered into as part of those agreements.  And in each case, the circuit courts circumvented these attempts, holding that the district court had erred in some way.  These cases are just a small part of a much broader debate about the use of monitorships.

Interestingly, a recent case reveals yet another concern regarding the government’s use of monitorships.  On March 29, 2018, a D.C. district court judge ruled in favor of a reporter who filed a “public-records suit,” which challenges the government’s authority to keep the names of individuals who were candidates to oversee monitorships secret.[12]  The reporter’s counsel argued that “the public has a strong interest in knowing exactly who is involved in the corporate compliance monitor selection process, including both who is nominated for these positions and who is evaluating those candidates.”[13]  The government argued that monitors who were not selected would be harmed and embarrassed by the disclosure.  Judge Rudolph Contreras disagreed, explaining that “while DOJ has demonstrated that these individuals have more than a de minimis privacy interest in their anonymity, the public interest in learning these individuals’ identities outweighs that privacy interest, and therefore the individuals’ names and firms must be released.”[14]

In past work, I have argued that whether a monitor’s reports should be protected by confidentiality versus disclosed to the public depended, at least in part, on the goals of the monitorship.[15]  The notion, however, that the identities of monitorship candidates should be kept protected, at least in my mind, does not seem worth the fight.  But the government’s ability to maintain its sole decisionmaking authority over monitorships has been upheld by the circuit courts to date; only time will tell whether the government will continue to prevail on these issues.

[1] SEC v. Am. Int’l Grp., 854 F. Supp. 2d 75, 77–78 (D.D.C. 2012), rev’d, 712 F.3d 1, 5 (D.C. Cir. 2013).

[2] Id. at 81–83.

[3] Veronica Root, The Monitor-“Client” Relationship, 100 Va. L. Rev. 523, 547 (2014).

[4] Am. Int’l Grp., 712 F.3d at 3–4.

[5] Veronica Root, Constraining Monitors, 85 Fordham L. Rev. 2227, 2231 (2017) (citing United States v. Fokker Servs. B.V., 79 F. Supp. 3d 160, 164 (D.D.C. 2015), vacated and remanded, 818 F.3d 733 (D.C. Cir. 2016)).

[6] Id.

[7] Fokker Servs. B.V., 818 F.3d 733.

[8] Root, supra note 5, at 2232.

[9] See United States v. HSBC Bank USA, N.A., No. 12-CR-763, 2016 WL 347670, at *4 (E.D.N.Y. Jan. 28, 2016), revd, 863 F.3d 125 (2d Cir. 2017).

[10] United States v. HSBC Bank USA, N.A., 863 F.3d 125 (2017).

[11] Id.

[12] Tokar v. U.S. Dep’t of Justice, No. 16–2410, 2018 WL 1542320 (Mar. 29, 2018) (mem.).

[13] Mike Scarcella, Justice Dept. Must Reveal Names of Unselected Corporate Compliance Monitors, Nat’l L.J. (Apr. 4, 2018),

[14] Tokar, 2018 WL 1542320, at *8.

[15] Veronica Root, Modern-Day Monitorships, 33 Yale J. Reg. 109 (2016).

Veronica Root is an Associate Professor of Law at University of Notre Dame Law School. Professor Root teaches Corporate Compliance & Ethics, Professional Responsibility, and Contracts.  Her scholarship on compliance and other matters is available here.

The views, opinions and positions expressed within all posts are those of the author alone and do not represent those of the Program on Corporate Compliance and Enforcement (PCCE) or of New York University School of Law.  PCCE makes no representations as to the accuracy, completeness and validity of any statements made on this site and will not be liable for any errors, omissions or representations. The copyright of this content belongs to the author and any liability with regards to infringement of intellectual property rights remains with the author.

Boeing Proxy Voting Recommendations

Corporate Governance -

Boeing, together with its subsidiaries, designs, develops, manufactures, sales, services, and supports commercial jetliners, military aircraft, satellites, missile defense, human space flight, and launch systems and services worldwide. Most shareholders do not vote because reading through 70 pages of the proxy is not worth the time for the small difference your vote will make. Below, […]

The post Boeing Proxy Voting Recommendations appeared first on Corporate Governance.

The New Standards for Investment Advisers and Broker-Dealers

Compliance Building -

One of the challenges that consumers face when dealing with a financial adviser is what it means to be a “financial adviser.” The terms financial planner, wealth consultant, stockbroker, investment adviser, financial consultant, and others get thrown around, leaving you how that person gets paid for helping you with your money.

The Securities and Exchange Commission is trying to help consumers with a trio of proposals.

On the Broker-Dealer side, the SEC is proposing Regulation Best Interest. This would create a new standard of conduct for broker-dealers and their representatives when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer. The proposed standard of conduct is to

  • act in the best interest of the retail customer
  • at the time a recommendation is made
  • without placing the financial or other interest of the broker-dealer or natural person who is an associated person making the recommendation ahead of the interest of the retail customer

This new standard would be satisfied if:

  1. broker-dealer, before or at the time of the recommendation reasonably discloses to the retail customer, in writing, the material facts relating to the scope and terms of the relationship, and all material conflicts of interest associated with the recommendation;
  2. broker-dealer, in making the recommendation, exercises reasonable diligence, care, skill, and prudence; the broker-dealer establishes, maintains, and enforces written policies and procedures reasonably designed to identify and at a minimum disclose, or eliminate, all material conflicts of interest that are associated with such recommendations;
  3. broker-dealer establishes, maintains, and enforces written policies and procedures reasonably designed to identify and disclose and mitigate, or eliminate, material conflicts of interest arising from financial incentives associated with such recommendations.

For item 1, there would be a new Form CRS. Broker-dealers would provide this to their clients.

For registered investment advisers, there would be a new Part 3 to Form ADV that would be Form CRS.

There is a lot in this package. SEC Chairman Clayton summarized them:

We propose to fill these gaps through (1) mandating clear disclosures — specifically, addressing how BDs and IAs identify themselves to investors and requiring them to provide investors with a standardized disclosure document of no more than four pages in length, highlighting among other things the principal services offered, legal standards of conduct that apply, fees the customer will pay, and certain conflicts of interest that exist, (2) raising the standard of conduct applicable to BDs to make it clear, among other things, that they cannot put their interests ahead of the interests of their retail customers, and (3) reaffirming, and in some cases clarifying, our views on the standard of conduct applicable to investment advisers.

There will be lots of commentary on these proposed regulations from all sides. One of those critics is SEC Commissioner Kara M. Stein:

 I am concerned that this rule will not only confuse retail investors, but also broker-dealers. In particular, the lack of a definition of best interest, the use of similar terms to mean different things, the use of different terms to mean the same things, and the possibility that the SEC and FINRA interpret the same language in their suitability standards differently. All of these concerns would make it difficult for the industry to discern a clear compliance path. Any resulting confusion may well result in higher compliance costs for broker-dealers, which will likely be passed onto the investor. What’s more, the lack of a clear standard is not likely to give investors more confidence in the broker-dealer business model.

There is over 1000 pages in these proposals. I’ll share more thoughts on them this week.


Elon Musk and the Control of Tesla

The Harvard Law School Forum on Corporate Governance and Financial Regulation -

Posted by Scott A. Barshay, Paul, Weiss, Rifkind, Wharton & Garrison LLP, on Monday, April 23, 2018 Editor's Note: Scott A. Barshay is a partner at Paul, Weiss, Rifkind, Wharton & Garrison LLP. This post is based on a Paul, Weiss publication by Mr. Barshay, Matthew Abbott, Ross Fieldston, and Stephen Lamb, and is part of the Delaware law series; links to other posts in the series are available here. Related research from the Program on Corporate Governance includes Independent Directors and Controlling Shareholders by Lucian Bebchuk and Assaf Hamdani (discussed on the Forum here).

Recently in In re Tesla Motors, Inc. Stockholder Litigation, the Delaware Court of Chancery (in an opinion by Vice Chancellor Slights) declined to grant defendants’ motion to dismiss because the court found it reasonably conceivable that Elon Musk, a 22.1% stockholder of Tesla Motors, Inc., was a controlling stockholder and therefore Tesla’s 2016 acquisition of SolarCity Corporation (of which Musk was the largest stockholder and founder) would be subject to a stringent entire fairness review. In this regard, it is rare for Delaware courts to find that a stockholder with such “relatively low” ownership levels is a controller. They have done so only, as was the case here, where there is other evidence that the stockholder exercised “actual domination and control over … [the] directors” and wielded more power than may be evidenced by the stockholder’s minority holdings. The court’s conclusion that Musk was a controller meant that stockholder approval of the acquisition did not ratify the transaction and invoke business judgment review because Corwin v. KKR Financial Holdings LLC does not apply to controller transactions.


Threat of Falling High Status and Corporate Bribery: South Korean Evidence

The Harvard Law School Forum on Corporate Governance and Financial Regulation -

Posted by Yujin Jeong (American University) and Jordan Siegel (University of Michigan), on Monday, April 23, 2018 Editor's Note: Yujin Jeong is Assistant Professor of International Business at American University Kogod School of Business; and Jordan I. Siegel is Associate Professor (Strategy Area) and Michael R. and Mary Kay Hallman Fellow at University of Michigan Ross School of Business. This post is based on their recent article, forthcoming in Strategic Management Journal.

What leads firms to engage in large-scale bribery of politicians? High-level politicians make decisions that shape the competitive landscape in the private sector, and recent years have witnessed a global surge in cases of blatant corruption involving prominent companies and senior politicians. But theory and evidence are scant about the firm-level determinants of corporate corruption involving large-scale bribes of top government officials. This study draws on sociology, behavioral economics, and criminology to examine what we call “threat of falling high status”—the condition in which a firm with longstanding high social status is threatened with an impending loss of status due to mediocre current economic performance relative to that of its industry peers. We examine whether this unexplored socioeconomic predictor can explain variability in large-scale corporate bribery of high-level government officials. Our article uses a novel data set from South Korea, where the internal accounting records of two presidents in the 1987–1992 era have been exposed to after-the-fact legal and public scrutiny.


FCPA Compliance and Ethics Report-Episode 380, Laura Perkins on issues around self-disclosure

FCPA Compliance & Ethics -

In this episode of the FCPA Compliance Report, I visit with Laura Perkins, a partner at Hughes Hubbard & Reed. Perkins formerly worked with the Department of Justice, FCPA Unit, departing in September 2017. We discuss the decision of self-disclosure of a potential FCPA violation to the Justice Department. Some of the highlights include: What [...]

The post FCPA Compliance and Ethics Report-Episode 380, Laura Perkins on issues around self-disclosure appeared first on Compliance Report.

Wendt and Sultan on oral downloads: What should counsel share with the SEC?

The FCPA Blog -

In prior posts, we covered (1) how two former General Cable executives, now defendants in an SEC enforcement action, sought to compel Morgan Lewis (General Cable’s counsel) to share interview memoranda and notes, investigation reports and other materials from the firm’s internal investigation, and (2) how Judge Jonathan Goodman ruled in the defendants’ favor in part by holding that Morgan Lewis had waived work product protections through oral disclosures of interviews to the SEC.

The Role of Executive Leadership and Data in Anti-Bribery Compliance

Richard Bistrong's Blog -

In part one of a two-part interview, John Arvanitis, Associate Managing Director for Compliance at Kroll, shares recent findings from the Kroll-Ethisphere Anti-Corruption and Benchmarking Report, as they pertain to leadership, data and cross-functional support. The full report can be found here: In this ten-minute interview, John addresses: The increase with respect to executive(...)

The post The Role of Executive Leadership and Data in Anti-Bribery Compliance appeared first on Richard Bistrong.

Tips to Achieve Consolidated Audit Trail (CAT) Compliance

Corporate Compliance Insights -

How to Overcome Technological Roadblocks What a time to work in the GRC field: new technologies are constantly emerging to help companies meet their regulatory obligations. At the same time, many fragmented requirements have piled up over time. Chris Ekonomidis, Head of U.S. Business Consulting at Synechron, discusses the three main hurdles organizations must overcome The post Tips to Achieve Consolidated Audit Trail (CAT) Compliance appeared first on Corporate Compliance Insights.

(This is only a summary. Click on the headline to view the entire article at Corporate Compliance Insights and participate in the discussion.)

What is Cryptocurrency and Who is Going to Regulate It?

Corporate Compliance Insights -

A Look at SEC, FINRA and Other Issues Cryptocurrency experienced massive and unprecedented growth in 2017, rising from a total market cap of $18.8 billion in January 2017 to $598.5 billion in December 2017. As of February 6, 2018, there were over 1,500 virtual currencies. The emergence of cryptocurrency has caused concern for regulators, who The post What is Cryptocurrency and Who is Going to Regulate It? appeared first on Corporate Compliance Insights.

(This is only a summary. Click on the headline to view the entire article at Corporate Compliance Insights and participate in the discussion.)

Starbucks and Lessons for the Compliance Practitioner in Risk Management

FCPA Compliance & Ethics -

There is not much more iconic in the US than Starbucks. As such they present some very visible and public lessons learned for the compliance practitioner. Recently Starbucks generated extremely negative news for having Philadelphia police arrest two persons who were waiting for a third person for a meeting. I want to use this most [...]

The post Starbucks and Lessons for the Compliance Practitioner in Risk Management appeared first on Compliance Report.

Why China is a Leader in Intellectual Property

BRINK News -

This is the first piece in a week-long series on intellectual property.

United States President Donald Trump is not the first to complain about intellectual property theft by Chinese companies, but ironically it was U.S. companies’ use of China’s resources that led to the development of its powerhouse of patents.

In the late 1980s and throughout the 1990s, Western firms such as Apple and Intel made large profits by investing in China to take advantage of the cheap labor, often at terrific human cost. As China’s economy grew and the population became wealthier, Western firms were then able to profit by selling their products back to the wealthier children of the same labor force that made them.

The Chinese government saw this happening and wanted Western firms benefiting from the Chinese market to give something back. It established a system of approving foreign investments on the condition that the businesses involved agreed to partner with local firms and transfer knowledge and skills to the local Chinese market.

In December 2001, when China joined the WTO, it entered into the Agreement on Trade-Related Aspects of Intellectual Property Rights to bring its IP laws up to a minimum international level. At the same time, the government was keen to transition from being a manufacturing-based economy to an innovation-based economy. This large step forward (as opposed to a great leap) would be fueled by expanding China’s domestically owned intellectual property.

One of China’s more controversial growth tactics has been to focus on fostering IP innovation within China. For example, the government preferences procurement of high-technology products whose IP is owned or registered in China.

This has been called a strategic attempt to commercialize non-Chinese ideas in China and a trade barrier potentially contravening China’s WTO commitments, including those under the Trade-Related Aspects of Intellectual Property Rights agreement.

In 2010, the Obama administration filed a complaint with the WTO over China’s use of its innovation policies in the wind power industry. There’s been other complaints lodged relating to Chinese IP laws—one in 2007 notably argued that China has failed to enforce IP laws on pirated products, even when they had been identified by victims and/or the Chinese authorities.

Since the late 1990s, China has been steadily improving the quality of its IP protection and the standard of its IP law enforcement. Many of its preferential policies favoring Chinese IP development have been wound back so as not to discriminate against foreign IP—or at least not so obviously. Other amendments have strengthened IP protection and enforcement, as well as increased penalties for IP infringements.

There remain many deficiencies in China’s protection of trademarks, copyrights, and patents.

In March 2017, for example, the General Provisions of the Civil Law were amended to make clear that trade secrets can be protected under civil IP laws. Amendments to the 1993 Anti-Unfair Competition Law in early 2017 also improved protection for trade secrets.

China’s most recent 13th Five-Year Plan, approved by the National People’s Congress in early 2016, envisions China as a world leader in science, high-tech and intelligent machines:

We will … expedite the implementation of existing national science and technology programs. … We will move faster to make breakthroughs in core technologies in fields including next generation information and communications, new energy, new materials, aeronautics and astronautics, biomedicine, and smart manufacturing.

Perhaps the best example of China’s goal of becoming a global leader in artificial intelligence is in the area of facial recognition technology. These systems, which automatically identify an individual from a database of digital images, are now a part of everyday life in China in areas such as public security, financial services, transport and retail services.

This technology is also just one aspect of a broader system being rolled out by the Chinese authorities. It aims to monitor and influence the whole of Chinese society (individuals and organizations) through social credit ratings.

The global facial recognition industry is forecast to be worth $6.5 billion by 2021, and its continued growth in China is being spurred by innovative startups such as YITU Technology and DeepGlint.

China knows that an essential part of achieving its aim of science and intelligent technology leadership is putting in place high quality legal protection for intellectual property. However, as recent reports from the United States have found, there remain many deficiencies in China’s protection of trademarks, copyrights, and patents.

IP enforcement in the case of piracy and other breaches is often inadequate. Either there is no prosecution of breaches, no positive finding that a breach has occurred or the penalty applied is too light to have any deterrence value.

However, for firms that do take the trouble to properly register their IP in China, protection does exist and enforcement is improving and will continue to improve.

This piece was previously published in The Conversation.

LPM Survey Results: Most report they have been assaulted when attempting to apprehend a shoplifter

Loss Prevention Media -

As part of last week’s LP Insider survey, we debated whether a loss prevention associate used excessive force in an encounter with a 16-year-old girl accused of shoplifting. The majority of those surveyed believed that the LP representative’s actions were justified based on the situation. Others believed that the LP representative should have allowed the shoplifter to leave when she resisted, and there were also a few respondents that felt that the actions of the LP representative were inappropriate.

While there may be some debate over how this particular situation was handled by the LP representative, another critical aspect of the incident involved the assault of the LP representative as he attempted to detain the shoplifter

The nature of the apprehension process always has the potential to lead to volatile situations. Yet despite employee training and company policies intended to mitigate these situations, incidents still occur on a regular and consistent basis that involve the assault of loss prevention professionals during the apprehension process—some leading to tragic results. Even for the most seasoned professionals, when shoplifters are faced with the threat of detainment and potential criminal charges, emotions can run high and individuals can be unpredictable.

Regardless of our current positions, most of those in loss prevention still have roots as representatives apprehending shoplifters. Has it ever happened to you?

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Get the facts about shoplifting in our FREE Special Report,Tips on How to Stop Shoplifting:   What You Can Learn from Shoplifting Statistics, Organized Retail Crime Facts & Shoplifting Stories right now!

Survey Results

A large majority of our survey respondents (87 percent) claim that they have been assaulted when attempting to detain a shoplifter despite following company guidelines and training, with 24 percent saying they have been assaulted once and 63 percent revealing that they have been assaulted on multiple occasions.

Approximately 10 percent indicate that while there have been situations that could have escalated further, they have always been able to detain shoplifters without being assaulted. Another 3 percent state that if the situation escalated to where they thought violence may result, they simply let the shoplifter go


Here is a sampling of your comments:

“Despite using proper guidelines, I have been punched and bitten by shoplifters.”

“This could have been prevented if other employees who were watching alerted me to an accomplice who kicked me in the head while taking a suspect into custody.”

“Many shoplifters can be escorted inside without incident or simply by using a calm, respectful tone and talking to them all the way back to the office. This keeps their mind occupied and lessens the likelihood of an altercation. However, regardless of taking every precaution and treating the subject in a respectful way there are those that will fight, argue, scream, or do anything they can to get away or create a scene.”

“We have to expect and prepare for the worst with every apprehension to protect ourselves and others nearby but we must also take the high-road and give them the chance to comply without problems. Should they decide to fight with us we have to very quickly assess whether to continue with the apprehension, which may include a struggle to get them restrained, or to let them go. Many times it’s a split-second decision, so it’s best to think it through beforehand by asking yourself- ‘what if’ so that you are prepared or have back up support ready just in case.”

“Yes. Despite what some in corporate offices seem to believe – shoplifters don’t always disengage just because you do. Even after we have disengaged, we have had shoplifters follow us back into the building attempting to fight us on numerous occasions – even with no physical contact initiated on our part.”

“Company policies ‘back in the day’ encouraged stopping shoplifters via physical force. While holding shoplifter down on ground, he bit me so hard that I had to get a tetanus shot.”

“Based off of pure fear of liability, companies have ‘tempered’ the LP position and people committing the crime of theft, credit card fraud, burglary etc. know it! Police departments have raised the dollar amount for grand theft, and oftentimes refuse to take a case for what it is. That action is based off of keeping crime statistics low and the city doesn’t look like it has a high crime rate.”

“Yes, I have had a few violent encounters from ORC groups and drug addicts. This is why I got out of the Loss Prevention industry. I don’t mind going hands-on with a resisting subject, but the standards and protocols for ‘hands-on’ apprehension are too abstruse and ambiguous. It serves to protect the corporation as a whole; but throws the agent under the bus with any liability pursuits from the criminal. The executives are at the top of the echelon, sitting behind their desks stating, ‘Well, we trained them, they knew the procedures,’ are the same ones terminating you once a subject gets physical.”

Do you have any additional thoughts? Let us know what’s on your mind.


The post LPM Survey Results: Most report they have been assaulted when attempting to apprehend a shoplifter appeared first on LPM.


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