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Internal Audit Director (Scottsdale, AZ)

Corporate Compliance Insights -

Job description Katerra is a technology company transforming property development, design, and construction—from start to finish. We are building an entirely new kind of company that brings together expertise in design, technology, material sourcing, manufacturing, and construction as a single integrated offering.With this unique approach, we have the opportunity to design and build beyond compromise. The post Internal Audit Director (Scottsdale, AZ) appeared first on Corporate Compliance Insights.

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Senior Risk Management & Compliance Manager (Basking Ridge, NJ)

Corporate Compliance Insights -

Job description What You’ll Be Doing… Corporate Risk Management and Compliance is responsible for the administration of Verizon’s Sarbanes Oxley compliance program, overseeing policies, processes, people and systems and partnering with business leaders to identify and mitigate financial, operational, legal, regulatory and reputational risks. The Senior Manager of RM&C is responsible for leading a team The post Senior Risk Management & Compliance Manager (Basking Ridge, NJ) 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.)

Why HR holds the key to creating the leaders of the future

Ethical Corporation Feeds -

No business leader wants to create more air pollution, lead more children to suffer health issues, or put more plastic in the ocean. For the most part, business leaders would like to be a force for good. Yet every day, the decisions and actions of business leaders across the world contribute to significant social and environmental challenges that put the future of our societies and economies at risk.

Image: Channels: Business StrategyTags: human resourcesUnileverNestlépurposeBlack RockOlamCISL

The Jury is Out on Compliance in the First Test of the Bribery Act’s Adequate Procedures Defence

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

by Omar Qureshi, Iskander Fernandez, and Amy Wilkinson

Last month saw the first contested prosecution of a corporation for failure to prevent bribery under section 7 of the U.K. Bribery Act 2010 (the “Bribery Act”), providing the first insights into how such a case may be argued and determined.  The defendant company Skansen Interiors Limited (“SIL”) was found guilty of failing to prevent bribery by one of its employees, who paid £10,000 (and offered, and tried to secure payment of a further £29,000) to another in order to secure two contracts for SIL.  The individuals involved had already pleaded guilty to substantive bribery offences.

A jury found SIL did not have adequate procedures designed to prevent bribery.  While the judge did not give her views on what may constitute adequate procedures and why SIL’s fell short, the jury’s verdict indicates that even small companies may need to have documented and targeted procedures in place, specifically addressing bribery prevention, if they are to succeed in proving an adequate procedures defence.


The Company

Prior to becoming dormant in 2014, SIL was actively trading as a fit-out refurbishment contractor in the South-East of England, primarily in London.  Its workforce comprised approximately 30 individuals, operating in an open-plan office based in one room at a single site. 

The Contracts

SIL was one of a number of contractors invited by a company named Debenham Thouard Zadelhoff (“DTZ”) to tender for two office refurbishment contracts in London worth a combined £6m.  SIL won the tenders in 2013.

The Bribes

The prosecution alleged that a project manager at DTZ had acted improperly during the tender process by passing SIL information that could have provided it with an advantage over its bidding rivals and/or sought to influence the award of the contracts by expressing a preference to his colleagues that SIL be selected.  The prosecution alleged that this was on the basis of offers/requests for bribes made to SIL’s managing director.

After SIL won the two contracts, it made two payments to the project manager totaling £10,000, and while a third payment of £29,000 was offered and requested, it was never paid, as explained below.

A number of steps were taken to conceal the nature of these payments and to make them appear genuine. Invoices for the three payments were sent to SIL by a separate company named Goodier Property Services Limited (“GPS”) that had been set up for the project manager and/or his son to receive them.  The invoices referred to the provision of “services in respect of final site surveys/drawings and final construction consultancy including CAD drawings and health and safety all as agreed”.  However, no services were ever provided by GPS.  Members of SIL’s senior management involved in the offence not only approved the invoices, but when their allocation to the projects was questioned, instructed the accounts team to reallocate the invoices to an unrelated internal cost code (as overheads under an overseas subsistence code).

The Internal Investigation

SIL appointed a new CEO in January 2014.  SIL’s managing director informed the new CEO about the arrangement with GPS, falsely explaining that it was legitimate and that the payments were for genuine services rendered.  He explained that a further payment of £29,000 was due on completion of the works under the two fit-out contracts.

Concerned with the explanation that had been provided, the CEO initiated an internal investigation. He also put in place an anti-bribery and corruption (ABC) policy, having found none in the company’s existing policies.  However, despite agreeing to abide by the new ABC policy, only a few days later the managing director attempted to approve and make the third payment of £29,000 to GPS.  That payment was stopped before it was made.

Following the internal investigation, the managing director and SIL’s commercial director (who was not charged by the police) were summarily dismissed.  SIL submitted a suspicious activity report to the National Crime Agency and also reported the matter to the City of London Police (COLP) and Action Fraud, asking them to investigate further.

COLP’s Investigation

During the police investigation, SIL provided extensive assistance and cooperation, voluntarily furnishing company documents, including confidential and potentially legally privileged reports and advice.  Some 20 months later, SIL was invited to be interviewed under caution and was subsequently charged under section 7 of the Bribery Act. SIL then instructed legal advisers to advise and assist it in defending the prosecution. The managing director and the project manager were charged with and pleaded guilty to the primary offences under sections 1 and 2 of the Bribery Act.

The Trial

SIL defended the prosecution on the basis that, through its various policies and other controls in the company, it had adequate procedures in place to prevent bribery by an associated person.  The defence relied on evidence that:

  • SIL was a very small business operating out of a single open-plan office that was smaller than the courtroom in which the trial took place – a company of that kind did not require substantial and sophisticated controls to prevent bribery for them to be adequate.
  • Similarly, SIL’s business area was very localised; they were not dealing with operations in multiple cities or countries with the cultural and oversight issues that that may entail – again indicating limited need for detailed controls.
  • It was common sense that one should not pay bribes and staff did not need a detailed, gold-standard policy to tell them that.
  • The ethos of the company, as exemplified by the junior finance clerk who gave evidence, was that everyone should behave with honesty and integrity, and it was reasonable for her to assume that the senior management of the company would do so.
  • Prior to its adoption of the ABC policy, SIL had a number of separate policies that had been in place for many years and which referenced the need for employees to approach their dealings with third parties in an ethical, open and honest manner.  These were sufficient – a separate ABC policy was not needed.
  • One such policy was printed on A3 laminated card and stuck to the walls of the office as a reminder to staff.
  • The financial controls, with its system of checks and balances that SIL had in place when approving and settling invoices were a procedure designed to ensure multiple approval levels before they could be posted on the company’s ledgers and/or paid.
  • There were clauses in the contracts to which the bribes related (based on standard JCT contract terms) that prohibited bribery and provided a right of termination of the contract where bribery occurred – therefore senior management were aware of the need to avoid committing bribery offences.
  • SB was specifically familiar with the need to avoid bribery and there was email evidence to demonstrate this.
  • SIL had stopped the largest of the bribe payments before it was paid, which indicated its procedures were in fact effective.

However, the jury members were not persuaded that these controls were sufficient to meet the adequate procedures defence under the Bribery Act. They returned a guilty verdict.  As SIL was dormant and without assets, the only sentence available to the court was to impose an absolute discharge, which under the provisions of the Rehabilitation of Offenders Act 1974 became immediately spent.

How Will Prosecutors Assess the Adequacy of Procedures?

This case illustrates the difficulties that small companies can face when seeking to implement controls for the prevention of bribery.  The verdict suggests that simply having a non-specific policy and normal accounting controls without incurring some cost and management time to implement targeted and specific bribery controls, introducing some bureaucracy into day-to-day operations, will be insufficient to afford even the smallest company the adequate procedures defence.   

While there was no judicial comment on what might constitute adequate procedures and why SIL’s procedures may have fallen short, the prosecutor’s submissions provide some insight into the way in which they may assess and argue the matter and highlight some questions that small (and larger) companies should ask themselves when assessing if their anti-bribery controls are sufficient:

  • Are all compliance efforts recorded? Historic offending events can bring with them evidentiary challenges – relevant staff may have left the business, people may not remember events in sufficient detail or documents may have been deleted by the time a prosecution is brought.  This can leave the company with a gap in knowledge and evidence of what policies and procedures were in place at the time of the offending conduct.  In this case, the prosecutor identified that there were few contemporaneous records of SIL’s efforts to inculcate a compliance culture or respond to the new offences in the Bribery Act.  It is therefore crucial to create and retain records of all compliance-related discussions and activities.  Even when it may be easier to have a conversation about such issues, it is advisable to follow up in writing (even in an informal note or email) or to document the fact those conversations occurred by recording them in calendar entries with sufficiently detailed descriptions to identify their purpose.
  • Have the company’s policies and procedures been properly communicated? The prosecution noted that while SIL’s various non-specific policies were available to all staff on its servers, SIL had not monitored or ensured that all staff had accessed or even read the policies, still less reminded themselves of the requirements over time.  There was no evidence of active communication or training on the policies.  The prosecution contrasted that approach with the way the new CEO introduced the ABC policy in 2014 – sending it to all staff by email and requiring them to use voting buttons to confirm their agreement to comply with it (and keeping those responses on staff HR records).  Companies should ensure that policies are effectively communicated to all staff and there is a paper trail evidencing that communication and training.
  • Is someone within the business responsible for compliance? The prosecution highlighted SIL’s lack of any explicit designation of an individual with responsibility for anti-bribery compliance at the time of the offending conduct.  Small companies without resource for a specialist compliance or legal function should ensure that there is someone within the business at a senior level tasked with ensuring the company’s anti-bribery controls are embedded within the business and complied with, even if it is not feasible to have a compliance specialist in this role.  Some record should be kept of that appointment and the appointee should keep records of his activities in that regard.
  • Is the company reactive to changes in the law or circumstances? The prosecution noted that SIL had failed to react to the introduction of the Bribery Act by putting in place a specific policy referencing the change in law or any other related processes.  Nor was the opportunity taken to circulate reminders to staff about the company’s expectations in respect of compliance.  Nor did the company provide any specific indicators or training on the sort of issues or “red flags” that staff should be alive to in their day-to-day activities.  Companies should use changes in law or circumstances (such as entering new territories or introducing new products) to revisit their existing compliance controls and satisfy themselves that they are still fit for purpose.  These reviews should be fully documented in case there is any later need to rely on and prove them.
  • Are reporting and approval lines appropriate? Staff must feel they are able to raise concerns when “red flags” are identified.  Where the issues relate to the actions of senior members of staff (as they did in this case), this can create a great deal of pressure on more junior staff members either to rely on assurances given by those who may be responsible for the unethical conduct or raise the matter with someone else within the business where that could increase the risk of them being identified as a whistleblower and retaliated against.  While not a point heavily relied on by the prosecution, SIL did not have a documented reporting channel that bypassed senior management when concerns may relate to them.  Small companies may wish to ensure the availability and communication of a channel for independent reporting of concerns, such as to non-executive directors (if any), who may be less likely to be involved in approving “red flag” transactions.

Other Points of Interest

This case is interesting, not only because it is the first contested case under section 7 of the Bribery Act, but also because of the CPS’s decision to prosecute the case at all:

  • In response to queries raised (including by the Judge in an earlier abuse of process hearing), the prosecution justified its use of public resources to charge and prosecute a dormant company with no assets on the basis that a successful conviction would “send a message” to others in the industry about the importance of having adequate procedures in place. 
  • However, an equally powerful message that may result from this prosecution, given that these matters were only discovered by the authorities because SIL itself reported them, is that companies who do the right thing by reporting criminality and assist the authorities in the prosecution of culpable individuals through the voluntary provision of evidence, may themselves be prosecuted rather than offered an alternative means of disposal.  Indeed, this may be a more likely outcome for smaller companies who are not ”too big to prosecute” and who cannot rely on wider negative public impact arguments about collateral consequences (such as job losses and concerns for the wider economy) to avoid a prosecution which would otherwise be justified.  This may have a negative impact on encouraging companies to self-report economic crime, something that the Serious Fraud Office in particular has sought to encourage since the introduction of deferred prosecution agreements (DPAs) in 2014. Indeed, this case may suggest that the CPS and SFO may take different approaches when assessing the public interest in prosecuting.
  • The CPS had determined that a DPA was not available in this case, as SIL was dormant and so there could be no ongoing benefit that could accrue from a DPA.
  • Despite the involvement of senior management (who were statutory directors of the company), the prosecution did not pursue the company under section 1 of the Bribery Act by arguing that the “directing mind and will” of the company was complicit in the bribery.  Unlike the section 7 offence, there is no defence to a section 1 offence.  This perhaps shows that the authorities are actively looking to challenge companies on their adequate procedures (or lack thereof), making it even more important for companies, even small businesses, to ensure their compliance programmes are sufficiently robust to persuade a jury that they are adequate.

* CMS Cameron McKenna Nabarro Olswang LLP’s Corporate Crime & Investigation’s Team acted in these proceedings on behalf of SIL. The original article can be viewed on CMS’ dedicated know-how site, LawNow, here.

Omar Qureshi is a partner at CMS Cameron McKenna Nabarro Olswang LLP. Iskander Fernandez is an associate and Amy Wilkinson is a senior associate at CMS Cameron McKenna Nabarro Olswang LLP

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.

Is ORC on the Rise? Just Ask Your Store Associates.

Loss Prevention Media -

If organized retail crime (ORC) continues to plague retailers as recent studies indicate, why are some retailers cutting their ORC investigative staff and seemingly losing their focus on preventing store loses and protecting their store associates and customers?

In the January-February 2018 issue of LP Magazine, author Garett Seivold penned the article “ORC is Worrisome, Worsening…And at Risk of Becoming Ignored?” Seivold noted that a recent National Retail Federation (NRF) ORC study indicated that retailers reported a “30 percent significant increase in ORC” while “7 percent said ORC decreased during the same time.”

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Now Is Not the Time to Lose Focus

From this author’s perspective, there is little doubt that ORC activity is in fact rising. While the NRF study certainly supports this assertion, corporate retail executives need only go into their stores to find this out first hand from their associates who are on the front lines daily battling this rising crime trend. It is in the stores that the even more concerning question of Servold’s article title becomes painfully relevant. Is ORC at risk of being ignored?

Most retailers will tell you that their company’s focus on shrink is cyclical. Shrink usually has to rise to an unacceptable internal level before senior company leadership focus on it. While there are some savvy retail executives who understand the delicate dance between driving sales and maintaining a healthy level of shrink, many executives don’t include the “S” word in their strategies for improving their company’s P&L.

As most are aware, shrink comes in many forms. ORC is just one of those forms. It has been argued that in the vast majority of retail environment, ORC is not the primary driver of store shrink. In grocery store environments, for example, perishable or fresh shrink typically holds the title of the top cost driver of shrink loss.

The importance of looking at all the components of store shrink or “total retail loss” as described by Professor Adrian Beck of the University of Leicester can’t be underestimated. As brick-and-mortar retail profits become even more pressured by e-commerce, the profitable retailers will be the ones who can incorporate the ideology of addressing total retail loss as part of their daily operational strategy.

Protecting Store Associates and Customers

If ORC is only a piece of the total retail loss equation, and in many cases not the driving loss leader, what is the concern about the loss of focus or even the acknowledgement of ORC as a shrink contributor? The answer is ORC impacts much more than loss of store merchandise and missed sales due to out of stocks. More importantly, it is about the safety of store associates and customers as well as the protection of a retailer’s brand image.

The NRF study reflected that 48 percent of respondents were seeing increased aggression exhibited by ORC thieves. Store associates and customers are in the direct line of fire, sometimes literally, of this aggressive behavior. This sobering reality should take the option of ignoring ORC off the table. But has it?

As noted above, the cyclical nature on the focus of addressing shrink practiced by many retailers can have a negative impact on controlling ORC losses. Plus, budget cuts are forcing some retailers to disband their ORC investigative units. The same budget cut challenges are also accounting for a reduction in law enforcement resources dedicated to address ORC activity.

To compound these investigative resource headwinds, legislative efforts across the nation have also played a critical role in hamstringing the efforts by retailers, law enforcement, and prosecutors in combatting ORC. The infamous Proposition 47 legislation that was passed in California set the standard for several states to follow-up suit and raise their felony threshold for retail theft offenses. Now many California citizens are seeing that some components of Proposition 47, like raising the retail theft threshold, were not such a good idea. Property crime has soared in many areas of the state because the same ORC recidivist offenders who were previously jailed for stealing from retailers are free to steal from the community at large.

Retail and Law Enforcement Must Partner

It appears obvious that ORC is a clear and present danger. If left unchecked, it is going to continue to grow in frequency, increasing the danger for store associates and customers as well as negatively impacting retail sales and profitability. The time has never been more critical for the retail industry and law enforcement to align on how to combat ORC in these challenging times.

If, as industry experts state, the most effective way to impact ORC offenders is with retailers and law enforcement working together to share intelligence and prosecute offenders, then it is time for a new, innovative approach to ensure these vital partnerships are not only in place but also are consistently used to their full potential to break the cycle of recidivist retail crime to promote safer stores and lower crime in the community.

The post Is ORC on the Rise? Just Ask Your Store Associates. appeared first on LPM.

What Happened to Toys “R” Us?

Loss Prevention Media -

September 2017: Toys “R” Us declares bankruptcy.

Early 2018: Toys “R” Us announces the closure of 180 stores.

February 2018: Toys “R” Us announces the closure of 200 more stores.

March 2018: Speculation abounds that Toys “R” Us will close all US stores and liquidate.

March 14, 2018: Toys “R” Us announces that it will close or sell all 800 of its US stores.

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I would bet that everyone reading this article has either shopped at Toys “R” Us or received a gift from Toys “R” Us. Founded in 1957 and morphing into its current format in about 1969, Toys “R” Us became the first mega “category killer” toy store. Most kids in the Seventies, Eighties and Nineties begged their parents to take them to Toys “R” Us. I know; I was one of those parents. The Toys “R” Us dominance of the toy market made small toy stores and hobby shops almost obsolete. Even KB Toys couldn’t keep up.

So, what happened? What went wrong? Some say bad planning. Some say bad luck. Probably both, but the real beginning of the end was the leveraged buy out of Toys “R” Us in 2005 by Bain Capital and KKR & Co. That leveraged buyout resulted in a staggering debt load of $6.6 billion for the company. This resulted in management distraction and put Toys “R” Us in a constant refinancing mode.

The tremendous growth in competition from Amazon and Walmart made things worse. With much deeper pockets, both retail giants began heavy discounting of toy prices to get parents to switch loyalties.

Then, add kids’ changing tastes to the mix. Toys “R” Us said “kids never want to grow up.” That may be partly true, but online video gaming and phone apps have taken a huge chunk out of the physical toy market. The financial crisis of 2008 and 2009 didn’t help matters.

The irony is that Toys “R” Us still sells millions and millions of dollars’ worth of toys, and toy sales rose 5 percent last year. But continued aggressive competition and the Toys “R” Us financial difficulties have taken their toll. Toys “R” Us continuing as a going concern is in doubt by most of the financial community. But there’s still hope. As of this writing, Toys “R” Us has officially announced the company’s liquidation, but it’s working on a possible plan to keep about 200 of its most profitable US stores open, according to CNBC. Can they make it? Maybe. Plans continue to evolve, and as of now, it’s unclear when exactly the doors will close.

The post What Happened to Toys “R” Us? appeared first on LPM.

Frank Brown on the Changing Global Compliance Environment [Podcast]

The Compliance & Ethics Blog -

By Adam Turteltaub The world is often a difficult place in which to do business.  Many countries lack the rule of law, are corrupt, and make it hard for a company to do business and to do so lawfully and ethically. The Center for International Private Enterprise (CIPE) is trying to make a difference.  […]

Breaking News in the Industry: March 15, 2018

Loss Prevention Media -

California Highway Patrol program catches L.A. cargo crooks

The California Highway Patrol Cargo Theft Interdiction Program (CTIP) in February arrested 15 members of a suspected theft crew in Los Angeles County following a seven-month investigation of organized commercial burglary. The total value of the stolen cargo was more than $1 million. Those arrested are alleged to have spent their days driving through industrial areas looking for merchandise, according to CTIP. At night they would return to likely spots, cutting holes into warehouse doors and loading stolen products into vans. Some businesses made the suspects’ jobs easier by leaving pallets of merchandise outside for quick pickup and delivery. The thieves targeted boxes of clothing, shoes, cosmetics and electronics and sold some of the merchandise to a Long Beach, California, couple. The CTIP said it expects to make more arrests in the case. The suspects were charged with grand theft and possession of stolen property. California formed the CTIP program in 1994. Security directors from such organizations as the Western States Cargo Theft Association, California Trucking Association and National Cargo and Security Council Transportation meet with law enforcement monthly to discuss recent trends, losses, suspects and active investigations.   [Source: Transport Topics]

Casino employee arraigned in Easter promotion scheme

A former host at Mohegan Sun Pocono casino in Pennsylvania accused of participating in a scheme to rig an Easter sweepstakes in 2014 was arraigned Tuesday. Kenneth Rowlands, 32, of Kingston, surrendered before District Judge Joseph Spagnuolo Jr. on charges of theft, receiving stolen property and criminal conspiracy to participate in a rigged contest. Spagnuolo arraigned Rowlands at Luzerne County Central Court and released him on $15,000 unsecured bail. Rowlands was accompanied by his attorney, Peter Moses. Authorities allege Rowlands was in on the scheme that involved two other casino employees — Robert Joseph Pellegrini, 52, a former vice president of player development, and Colin Ray Boecker, 32 — plus casino patron Mark Heltzel. According to criminal complaints: Boecker set up the Easter sweepstakes, which offered patrons the opportunity to select plastic eggs that contained cash prizes and free slot credits. Rowlands had to make sure Heltzel was made aware that a certain egg contained the grand prize of $10,000, which he picked on April 27, 2014. Heltzel then gave some of the cash to Pellegrini, Boecker and Rowlands. Boecker, of Tonawanda, New York, and Pellegrini are facing similar charges. They have not been arraigned.Heltzel, 53, of Dallas, has not been charged in this case, but pleaded guilty in another. The alleged contest rigging happened before Pellegrini was involved another scheme with Heltzel and former casino waitress Rochelle Poszeluznyj, 40, of Kingston. Pellegrini, Heltzel and Poszeluznyj were charged in 2016 in the scheme that ran from May 2014 to April 2015 and involved the theft of personal identification numbers, or PINs, from gamblers. The numbers were then used to create duplicate rewards cards with $478,000 in free play credits. Heltzel gambled with the cards and split the winnings with Pellegrini and Poszeluznyj who stole the PINs. Heltzel was sentenced last August to 18 months in federal prison. Poszeluznyj was sentenced to six months on house arrest and two years on probation.[Source: Times Leader]

Toys ‘R’ Us will sell or close all US stores, according to CEO

Toys “R” Us is set to file liquidation papers Wednesday (March 14) evening in advance of a bankruptcy court hearing on Thursday, reported The Record. Toys “R” Us CEO David Brandon spoke about the company’s fate to employees in a conference call, calling it a sad day, according to the report. He also said the brand would be missed. However, the decision to liquidate might not sink the retailer totally. CNBC reported that the toy giant is eyeing one plan that would keep some stores open ever after it liquidates the company. Under the proposal, the company would sell its stronger Toys “R” Us Canadian division, along with some 200 of its most profitable US stores, to a new buyer. Although there is no definite buyer yet, there are several circulating, according to CNBC. Toys “R” Us, which filed for bankruptcy in September, currently has more than 700 remaining US locations, between its namesake and Babies “R” Us banners. In related developments, the U.K. arm of Toys “R” Us on Wednesday announced it will be closing its store base within six weeks. [Source: Chain Store Age]

Man robs JCPenney store, threatens LP associate with knife

Police in San Antonio, Texas, arrested a 33-year-old man after he allegedly robbed a JCPenney and threatened a loss prevention associate with a knife. Investigators say Roland Pena was caught on camera stuffing a pair of jeans inside a shopping bag at South Park Mall on SW Military Drive around 1 p.m. on February 22nd and then putting on a new pair of shoes before walking toward the elevator. A police affidavit states Pena was confronted by a loss prevention associate, who said Pena took off the shoes but kept the jeans in the bag. Investigators say Pena pulled out a knife as he walked toward the store exit and told the LP associate to stop following him. Pena has been charged with aggravated robbery. [Source: News4SA]

Retail jobs increased by over 46,000 in February

Retail industry employment increased by 46,400 jobs in February over January, the National Retail Federation (NRF) said today. The number excludes automobile dealers, gasoline stations and restaurants. Overall, the economy added 313,000 jobs, the Labor Department said. “This substantial gain in retail jobs is a significant positive sign regarding the health and viability of the industry,” NRF Chief Economist Jack Kleinhenz said. “It is stronger than expected and there were broad gains across most retail sectors. Beyond retail, labor markets continued to strengthen in all industries in February, and more jobs throughout the economy will mean more consumers shopping in retail stores. With tax reform in effect, consumer confidence increasing and strong underlying economic fundamentals, 2018 is off to a good start and we expect a prosperous year ahead.”The February increase was more than four times the gain of 10,800 jobs seen in January over December. The three-month moving average in February showed an increase of 10,600 jobs.

General merchandise stores were up by 17,700 jobs, fueled mostly by gains at warehouse and supercenter stores, while clothing and accessories stores were up by 14,900 jobs and building materials stores were up by 10,300 jobs. There were declines totaling 5,400 jobs spread across health and personal care, sporting goods and miscellaneous stores. Kleinhenz noted that retail job numbers reported by the Labor Department do not provide an accurate picture of the industry because they count only employees who work in stores while excludng retail workers in other parts of the business such as corporate headquarters, distribution centers, call centers and innovation labs. Economy-wide, average hourly earnings in February increased by 68 cents – 2.6 percent – year over year. The Labor Department said the unemployment rate was 4.1 percent, unchanged for the fifth straight month. [Source: Business Wire]

ATM debit card fraud hit 10 percent in 2017

A new report has revealed that there was a 10 percent increase in the number of payment cards compromised at US ATMs and merchants in 2017. “The number of compromises and the number of card members impacted set a new record last year,” said TJ Horan, vice president of fraud solutions at FICO. “While most devices are safe, fraudsters are developing new technology and methods for hacking ATMs. This is why it’s important for consumers to be cautious when withdrawing cash, and also for them to check their account regularly and confirm that all the transactions on their debit card are legitimate.”The data – which is taken from the FICO Card Alert Service that monitors hundreds of thousands of ATMs and other readers in the US – also showed that compromised card readers at US ATMs, restaurants and merchants went up 8 percent in 2017.

ATM hacks have proven to be a real concern for consumers and financial institutions. Earlier this year, Diebold Nixdorf and NCR Corporation – the two biggest ATM makers in the world – warned that hackers are going after ATM machines in the US with tools that can force the machines to spit out cash. A confidential alert was sent to banks from the U.S. Secret Service that hackers are targeting standalone ATMs that are usually found in drug stores, big-box retailers and drive-thru ATMs. And while financial institutions are launching cardless ATM transactions in which customers can use their mobile phones to withdraw money, Krebs on Security found that feature can be hacked, with criminals using stolen bank account usernames and passwords to quietly take cash out of ATMs. In its report, FICO offered tips to keep payment card info safe, including staying away from an ATM that looks odd, or where your card doesn’t enter the machine smoothly; avoiding an ATM if anyone is hanging around nearby; calling your bank immediately if your card is captured inside of an ATM; requesting a new card number if you believe your card has been compromised; and checking your transactions frequently. [Source: PYMNTS]

The post Breaking News in the Industry: March 15, 2018 appeared first on LPM.

Q&A: Cape Town’s ‘Day Zero’

Risk Management Monitor -

On March 22, annual World Water Day will be especially relevant, as the United Nations and its co-sponsors hope to raise global awareness of water risks—particularly in Cape Town, South Africa. As we previously reported, a diminishing water supply is that city’s top priority, as it is counting down to a possible “Day Zero” (which had been set for July 9, but the City has stopped providing a date), when it could effectively become the first major city to run dry.

One of World Water Day’s partners is World Wide Fund For Nature South Africa (WWF-SA), an arm of what was formerly known as the World Wildlife Fund. Christine Colvin, senior manager of Freshwater for WWF-SA, recently discussed Cape Town’s struggles and how other major cities and businesses can learn from the preparedness plan and efforts to avoid a total drought.

Risk Management Monitor: Cape Town, which has 4 million residents, has a preparedness plan in effect that includes rationing among 200 water distribution points for 25 liters per person. Do you feel this plan is sustainable?

Christine Colvin: At this stage, the general consensus is that Day Zero is not as imminent a threat as it was earlier in the year, and in all likelihood, there will be some rain and augmentation schemes will start to come online before dams drop to the critical 13.5% (which would activate the disaster plan). Consequently, the major

push is to encourage citizens to stay within their current daily limit of 50 liters of water per person, per day to see us through to the rainy season and beyond. If we are able to achieve this objective, the hope is that we should push out Day Zero as far as possible, thus buying the city time to bring on augmentation schemes.

RMM: How could Cape Town officials explore nature-based solutions (this year’s World Water Day campaign) to its water challenges?

Colvin: Ecological infrastructure is the foundation of water security and the first link in the water value chain. If our catchments are healthy and functional they deliver better quality, more reliable yields of water into our dams and aquifers. If they are invaded with alien vegetation or degraded by over-grazing or over-burning then they yield less water and more silt that will eventually destroy any downstream infrastructure we build to deliver water to our homes and farms. WWF-SA actively advocates the protection of water source areas through, among other things, water stewardship and catchment clearance of alien vegetation and has actively communicated this approach to the City of Cape Town during this drought period.

In our communications to the general public, we also encourage better stewardship of existing natural water sources such as groundwater and rivers, and promoting a water-wise culture. Our stewardship work in the Western Cape, the province in which Cape Town is located, focuses strongly on the agricultural sector which is a key industry for the region.

RMM: What steps can a major city take to prepare for a drought?

Colvin: Our Wednesday Water File on international case studies highlights many pertinent actions, perhaps best summarized in the Australian example:

  • Invest in fixing leaking infrastructure—one of the most cost-effective measures to improve water supplies
  • Introduce a demand management program which includes strict new legal requirements on business and domestic water use, coupled with a major education campaign
  • Diversify water supplies so if one source fails others can be drawn on, among them: dams, desalination, recycled water, rainwater tanks, groundwater, and storm water harvesting
  • Create a water grid which links major regional water supplies so water can be moved to where it is needed 

RMM: How is World Water Day raising awareness to the situation in Cape Town?

Colvin: While water is top of mind in Cape Town, the intention is to remind all South Africans that we live in a water-stressed country and the protection of strategic Water Source Areas and their natural capital is a national project. Water source areas are particularly important—making up 8% of South Africa’s land area but delivering 50% of our river flow to the rest of the country. Good management of these high rainfall mountainous headwater areas delivers a high return on investment downstream.

World Water Day is an important time to reflect on the relationship between water and nature. Many, but not all, residents of Cape Town are now aware of the “new normal” in which we are likely to experience much drier periods and have to conserve water but it remains vital to reinforce the message that water does not come from a tap—it comes from nature.

Statement on Proposed Amendments to Public Reporting of Fund Liquidity Information

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

Posted by Jay Clayton, U.S. Securities and Exchange Commission, on Thursday, March 15, 2018 Editor's Note: Jay Clayton is Chairman of the U.S. Securities and Exchange Commission. This post is based on Chairman Clayton’s recent public statement, available here. The views expressed in this post are those of Mr. Clayton and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Today [March 14, 2018], the Commission will consider a proposed rule that would amend the liquidity risk management rules for open-end funds that the Commission adopted in October 2016. Specifically, staff will recommend that the Commission propose amendments to revise the manner in which information about funds’ liquidity risk management practices is provided to investors in those funds. These recommendations are designed to address the potential for investor confusion presented by a few aspects of the current rule.


Spring Awakening: Notes from This Year’s CII Meeting

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

Posted by Nell Minow, ValueEdge Advisors, on Thursday, March 15, 2018 Editor's Note: Nell Minow is Vice Chair of ValueEdge Advisors.

The theme I heard most often at the annual spring meeting of the Council of Institutional Investors was ESG: environmental/social/governance risks and investment opportunities. The issues of how best to understand ESG and factor it into assessing investment risk and return and how to respond as investors through proxy voting or engagement came up in a number of contexts. Other issues that were raised more than once included voting rights, crypto-currencies and initial coin offerings, and international investments and investors.

Some of the highlights of the official and member-hosted side meetings:


Overview of Proposed Revisions to the UK Corporate Governance Code

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

Posted by Jason Halper, Steven Baker and Janaki Tampi, Cadwalader, Wickersham & Taft LLP, on Thursday, March 15, 2018 Editor's Note: Jason Halper and Steven Baker are partners and Janaki Tampi is an associate at Cadwalader, Wickersham & Taft LLP. This post is based on a Cadwalader publication by Mr. Halper, Mr. Baker, Ms. Tampi, Ellen Holloman, Jared Stanisci and Hyungjoo Han. Related research from the Program on Corporate Governance includes The Elusive Quest for Global Governance Standards by Lucian Bebchuk and Assaf Hamdani.

In December 2017, the UK Financial Reporting Council (the “FRC”) proposed revisions to the UK Corporate Governance Code. These revisions will impact companies with a Premium Listing of equity shares in the UK, which are required under the Listing Rules to state in their annual report and accounts how they have applied the Code. The revisions are designed to achieve long-term company growth through enhanced corporate accountability mechanisms and are aimed at consolidating the UK’s reputation as a leading environment for transparent and efficient international business. Many of the proposed revisions, if enacted, would facilitate greater alignment between UK and US corporate governance law and regulations.


In December 2017, the FRC published proposed revisions to the UK Corporate Governance Code (the “current Code”). The changes follow the August 2017 announcement by business secretary Greg Clark that the UK Government would be implementing wide-ranging corporate governance reforms in response to its November 2016 Green Paper Consultation on Corporate Governance Reform, the subsequent FRC report on corporate culture and the Business Enterprise and Industrial Strategy report on corporate governance.


3 Keys to Successful GRC Programs

Corporate Compliance Insights -

Q&A with Brad Bussie, Principal Security Strategist at Trace3 Today we feature an interview with between Maurice Gilbert, CCI’s CEO, Founder and Publisher, and Brad Bussie, Principal Security Strategist at Trace3, a provider of IT solutions and consultation services. The company’s thriving security practice helps companies review and manage internal policies and protocols to develop an integrated approach The post 3 Keys to Successful GRC Programs 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.)

A Survey on Corporate Governance

CGI – Corporate Governance Institute -

This survey has its origins in a book that we (Anil Kariwala, Robert Purse & Graham Smedley) are currently writing. Rather than simply relying upon anecdotal evidence and personal experience, we decided to undertake some survey-based research and hence the survey, which was open for responses during the first half of June 2015. The survey […]

The post A Survey on Corporate Governance appeared first on CGI - Corporate Governance Institute.

Brief Review of the Newly Revised Chinese Anti-Unfair Competition Law

Global Compliance News -

On 4 November 2017, the Anti-Unfair Competition Law of the People’s Republic of China (the AUCL) was amended for the first time since its promulgation and implementation 24 years ago in 1993, and the revised AUCL (the Revised AUCL) came into effect on 1 January 2018. Since announcing the proposed revision of the AUCL, there have been heated discussions, especially within and amongst intellectual property related industries and professionals. The revisions to the AUCL reflect changes to and developments in the socialist market economy over the past two decades, and specifically seek to refine legal concepts in the area of anti-unfair competition law, increase the legal responsibilities of business operators and strengthen enforcement measures, so as to create a more advanced anti-unfair competition system.

As the amendments to Article 2 (on the scope of applicability of the AUCL), Article 6 (on “confusing behaviors”), Article 9 (on trade secret violations) and Article 12 (on unfair competition activities committed on the internet) are particularly worthy of note, the abovementioned amendments will form the subject of the discussion below.

I. Article 2 of the Revised AUCL – refinement of its scope and clarification that it operates as a “catch all” provision

In practice, Article 2 of the AUCL was often used as a general catch-all provision, and played an important role in “catching” new or atypical acts of unfair competition.

In a draft revision of the AUCL, attempts were made to clarify the applicability of Article 2. Originally, draft Article 15 provided that with regard to behavior which has a serious adverse impact on the competitive environment and in respect of which the applicability of Article 2 falls to be considered, the Administration for Industry and Commerce under the State Council shall, independently or together with relevant departments under the State Council, investigate and render an opinion on whether the act should be regarded as an act of unfair competition, and report the same to the State Council for its decision. However, as such an amendment would increase uncertainty and the difficulty in applying Article 2, draft Article 15 was not adopted. Instead, Article 2 was revised, and Article 17 included to confirm that legal liability will attach to all acts of unfair competition which compromise the legitimate rights and interests of business operators. Such amendments enlarge the scope of Article 2, and in the eyes of many academics and practitioners, confirm that Article 2 of the Revised AUCL is a general provision that can be directly relied upon.

II. Article 6 of the Revised AUCL – clarification of the term “confusing behavior”

1. Meaning of “confusing behavior”

Article 6 of the Revised AUCL replaces Article 5 of the AUCL, and no longer includes paragraphs (1) and (4) in Article 5. As a result of the amendments, “counterfeiting another’s registered trademark” and “forging or fraudulently using quality marks on goods, or geographical indications, so as to mislead consumers as to the quality of the goods” will no longer be considered acts of unfair competition. The deletions aim to clarify the boundaries between, amongst other laws, the Revised AUCL, the PRC Trademark Law and the PRC Product Quality Law.

Further, the revised Article 6 elaborates on the meaning of “confusing behavior”. Behaviour is only “confusing” if it is or is likely to be misleading in that it causes or is likely to cause another to misidentify the source of the goods or to mistakenly believe that there exists some sort of connection between the goods and the brand owner. Under Article 6, there are four types of “confusing behavior”, the first three of which are deemed to have the effect of misleading people in the abovementioned manner: (1) using or copying the name, packaging or decoration of another’s famous goods, (2) using another’s trade name, (3) using another’s domain name, website name or any other name in the internet context, and (4) other confusing behaviors. Type (4) is a residual open-ended category and would catch for instance the use / copying of the overall appearance of another’s goods, the names and colour schemes used in the marketing of another’s goods etc., provided that confusion can be established.

Additionally, previously, Article 5 required the “name, packaging and decoration of famous goods” to have achieved “well-known status” under sub-section (2) of paragraph 1 before they could be afforded protection, whereas this “well-known status” requirement did not apply to other names, such as trade names (though a Supreme People’s Court interpretation stipulated that only those trade names that are known to the relevant public and enjoy a certain degree of fame could be afforded protection). Now, instead of imposing a “well-known status” requirement, Article 6 of the Revised AUCL imposes a “certain degree of influence” requirement, which extends to all types of names. Such amendment is logical as it is only when names, indications etc. have achieved a certain degree of influence and are familiar to the public that confusion can arise.

The “certain degree of influence” requirement sets a lower threshold than the “well-known status” requirement. For further guidance as to what the “certain influence” requirement entails, reference can be made to Article 32(1) of the PRC Trademark Law (re prior use of trademarks with a certain degree of influence), and the way in which the provision has been applied in practice.

2. Stipulation of the legal consequences for engaging in confusing behavior and provision for harsher administrative penalties

Article 18 of the Revised AUCL clearly stipulates the potential legal consequences that could follow from violating Article 6, including an order to cease the infringing acts, a confiscation order in respect of the infringing commodities, and/or administrative fines. Article 18 also increases the maximum amount of administrative fines that can be imposed, from up to three times the amount of the illegal turnover to, if the illegal turnover is greater than RMB 50,000 (approx. USD 7,400), up to five times the amount of the illegal turnover, and if the illegal turnover is less than RMB 50,000 or if no illegal turnover is generated, up to RMB 250,000 (approx. USD 37,000).

3. More practical legal measures to correct confusing trade names

In practice, some enterprises take advantage of loopholes in the trade name registration system to register another’s registered trademark or trade name as one’s own trade name. Such registrations easily cause consumer confusion and infringe upon the lawful rights of prior right-holders.

Article 58 of the PRC Trademark Law, which came into effect on 1 May 2014, provides that: “Where one uses another’s registered trademark or unregistered well-known trademark as or in one’s own trade name in a manner that misleads the public and results in unfair competition, such matter shall be handled in accordance with the PRC Anti-Unfair Competition Law.” Article 6(2) of the Revised AUCL corresponds with Article 58 of the PRC Trademark Law.

However, prior right-holders often face problems enforcing administrative and judicial decisions, mainly because the current legal regime requires the infringing entity registering or using the prior right-holder’s name to be the one to change or deregister the infringing trade name, and in many cases, the infringing party refuses to cooperate. Article 18(2) of the Revised AUCL aims to rectify this legislative shortcoming by providing that: “Where a registered trade name is in violation of the provisions of Article 6, the registrant shall apply for a change of name in a timely fashion. Before the change is effected, the original enterprise registration authority shall replace the registrant’s name with its uniform social credit code”. This provision for the first time clearly stipulates in legislation specific administrative corrective measures that are to be taken to combat inappropriate trade names, which will be of help in the fight against copycat brand names.

Having regard to this change, prior right-holders should, when they initiate civil litigation against infringing parties, request the infringing party to change its trade name, rather than deregister its infringing trade name. Otherwise, the administrative authorities responsible for effecting the name change may refuse to cooperate on the basis that the court decision requires deregistration instead of modification.

As mentioned above, under the Revised AUCL and other relevant regulations, prior right-holders can require the original enterprise registration authority to replace the infringing party’s trade name with its unified social credit code on the State Enterprise Credit Information Disclosure System if the infringing party refuses to change its trade name. However, even if the original enterprise registration authority replaces the infringing party’s trade name with its unified social credit code, it remains to be seen what would happen if the infringer continues to use the infringing trade name. The infringer may still possess and use its business licence and other certificates listing the infringing trade name, and the administrative management authorities will need to issue additional regulations to address this issue.

III. Article 9 of the Revised AUCL – trade secrets

The Revised AUCL broadens the definition of “trade secrets”, from one which requires the secret to have “practical value” to: “… technical information or business information which is unknown to the public, has commercial value and in respect of which the right owner has taken corresponding measures to ensure its confidentiality.”

Additionally and more importantly, the Revised AUCL makes provisions for third-party infringement in cases where the proprietor of the trade secret is the employer of the trade secrets infringer. Under the Revised AUCL, a third party will be held to have infringed upon a proprietor’s trade secret if the third party was aware that the proprietor’s employee or ex-employee, another organization or an individual had obtained the trade secret through illegal means. This is a commendable improvement as it increases protection of employers’ trade secrets and deters third-party infringement.

Another important change is the increase in penalties for violating trade secrets. Under Article 17 of the Revised AUCL, the maximum statutory compensation payable in civil cases is now RMB 3 million (approx. USD 441,000), up from RMB 1 million (approx. USD 147,000). Furthermore, administrative penalties have increased under Article 21 of the Revised AUCL, and parties who have violated trade secrets are now liable to be punished with fines of between RMB 100,000 and RMB 500,000 (approx. USD 15,000 to USD 74,000), or between RMB 500,000 and RMB 3,000,000 (approx. USD 74,000 to USD 441,000) in serious cases. Finally, the revised law requires authorities to maintain the confidentiality of trade secrets during investigation.

IV. Article 12 of the AUCL – addition of new provisions on internet related unfair competition activities

With the continuous development of social and economic conditions as well as the internet in China, a large number of cases in respect of internet related unfair competition activities have arisen. Previously, the good faith principle under Article 2 of the AUCL was often used by courts in such cases. However, Article 12 of the Revised AUCL now specifically addresses unfair competition activities conducted on the internet, which are specified to include (1) inserting links to a network product or service offered by another without that other’s consent, which, when clicked on, automatically redirect the user to pages of other targets; (2) misleading, deceiving or forcing users to revise, shut down or uninstall a network product or service offered by another; (3) maliciously making a network product or service offered by another incompatible with one’s own products or services, and (4) engaging in any other act that interferes with or sabotages the normal running of a network product or service offered by another.

Article 12(1) to (3) is a codification of recent important court decisions, such as Baidu v Qihoo (the flagging search results and hijacking traffic case) ((2014) Min Shen Zi No. 873) and Tencent v Qihoo (the “Kou Kou Bodyguard” case) ((2013) Min San Zhong Zi No. 5). As an exhaustive list cannot comprehensively capture every act of unfair competition committed on an evolving internet with constantly changing technologies and business models however, Article 12(4) was also included to serve as a catch-all provision to cover unforeseeable internet cases.

In terms of the penalties that can be imposed for engaging in acts of unfair competition on the internet, Article 24 of the Revised AUCL sets out the administrative penalties. In respect of civil liabilities, unlike Article 6 (re engaging in confusing behavior) and Article 9 (re violating trade secrets), the newly Revised AUCL does not set out a statutory compensation scheme for violations of Article 12, and in previous unfair competition cases involving the internet, courts have awarded compensation of up to RMB 5 million (approx. USD 735,000) (e.g., Tencent v Qihoo “Kou Kou Bodyguard” case)

In sum, the newly Revised AUCL provides more specific guidance on what constitutes “confusing behavior” and an act of unfair competition on the internet, and also adopts broad descriptions and catch-all provisions to address new forms of unfair competition in the market. Additionally, the AUCL increases penalties for specific acts of unfair competition and provides for more practical remediable measures to be adopted. These provisions will help maintain market order and the competitive environment, and safeguard the legitimate interests of business operators. We await application of the relevant provisions and measures by way of administrative and judicial enforcement, to further clarify the meaning and applicability of provisions of the Revised AUCL.

The post Brief Review of the Newly Revised Chinese Anti-Unfair Competition Law appeared first on Global Compliance News.

Director of Compliance for International Pharma in Chicago

Corporate Compliance Insights -

Conselium is representing a premier international pharmaceutical company, in the Chicago Area, with consistent revenue growth and 5-year income growth of 92%.   Our success is built on a strong pipeline of products; we achieve this by our commitment of 17% of revenues to R&D. Why Join Us: Consistent leader in outperforming industry in revenue and The post Director of Compliance for International Pharma in Chicago 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.)


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