"Public Trust in Business: Research and Implications of the Important Factors in Developing Trust"
Dean Krehmeyer, Executive Director, Business Roundtable Institute for Corporate Ethics; and Kirsten Martin, Assistant Professor, The Catholic University of America
From: RDShatt@aol.com
To: BRICE@darden.virginia.edu, martink@cua.edu
Sent: 9/4/2011 12:01:40 P.M. Central Daylight Time
Subj: "Public Trust in Business: Research and Implications of the Important Factors in Developing Trust"
Dear Mr. Krehmeyer and Professor Martin,
Your above topic at the Ethics & Compliance Officer Association annual conference later this month is broad ranging, and it should be interesting how you will present it to ethics and compliance professionals.
I am a citizen activist in the business ethics field, and I offer the following thread between your topic and ethics and compliance:
I believe there is an important question about entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing.
I further believe that corporate management, on the one hand, and ethics and compliance officers, on the other, could have differing views about the same.
I think this is a complex subject that likely entails significant countervailing considerations. Also, other parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, various academics, plaintiffs' lawyers, and consumer protection organizations.
My further belief is that the foregoing parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I don't know if you see a thread here that connects up with public trust in business. I think there is a thread. I hope you will take the time to explore it.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Earning a Seat at the Table: Navigating the Perilous Waters of Organizational Power and Politics"
Bill Prachar, Partner, Compliance Systems Legal Group; Susan Ponce, Senior Vice President and Chief Compliance Officer, Halliburton; and Earnie Broughton, MBA Program Director, Bill Greehey School of Business, St. Mary’s University
From: RDShatt@aol.com
To: bprachar@CSLG.com, susan.ponce@halliburton.com, ebroughton@stmarytx.edu
Sent: 9/4/2011 4:00:26 P.M. Central Daylight Time
Subj: "Earning a Seat at the Table: Navigating the Perilous Waters of Organizational Power and Politics"
Dear Mr. Prachar, Ms. Ponce, and Mr. Broughton,
I hope you have some good ideas to present at the Ethics & Compliance Officer Association annual conference later this month for how ethics and compliance officers can gain a seat at the table.
I frankly think there are obstacles that will be extremely difficult to overcome.
I suggest those obstacles can be usefully explored if you think about the important question of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing, and whether corporate management, on the one hand, and ethics and compliance officers, on the other, are likely, in the end, to have differing views about the same.
I believe this is a complex subject that likely entails significant countervailing considerations. Also, other parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, various academics, plaintiffs' lawyers, and consumer protection organizations.
My further belief is that the foregoing parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I don't know if you wish to parse through the factors and considerations here that bear on the matter of "earning a seat at the table.". I hope you will attempt the exercise.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"When It Gets Personal: Advice to In-house Counsel on Avoiding Criminal and Civil Liability"
Z. Scott, Partner, Kaye Scholer LLP; and Patricia BrownHolmes, Partner, Schiff Hardin LLP
From: RDShatt@aol.com
To: z.scott@kayescholer.com, pholmes@schiffhardin.com
Sent: 9/5/2011 9:36:19 A.M. Central Daylight Time
Subj: "When It Gets Personal: Advice to In-house Counsel on Avoiding Criminal and Civil Liability"
Dear Mr. Scott and Ms. Holmes,
The above title of your presentation at the Ethics & Compliance Officer Association annual conference later this month is suggestive that personal liability has a special potency in getting a corporate actor's attention and in guiding that actor's conduct.
I agree with that. I also believe that ethics and compliance professionals have generally not given adequate consideration to the matter of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous other parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, various academics, plaintiffs' lawyers, and consumer protection organizations.
My further belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
Inasmuch as your ECOA conference topic specifically calls attention to the special potency of personal liability regarding in-house counsel, I hope you also entertain thoughts of the significance of the same relative to all corporate actors and deterring corporate wrongdoing.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"From Values to Compliance: Bridging the Gap,or a Bridge Too Far?"
LeeAnn Pelham, former Executive Director, Los Angeles City Ethics Commission
From: RDShatt@aol.com
To: ethics.commission@lacity.org
Sent: 9/5/2011 10:01:02 A.M. Central Daylight Time
Subj: Please forward to LeeAnn Pelham
[To the Ethics Commission: I know Ms. Pelham is the former Executive Director and may no longer have any connection with the Commission. I cannot find an email address for Ms Pelham, and thus I am sending this email with the request that it be forwarded to Ms. Pelham. If the Commission is not in a position to do that, I will understand. Thank you. Rob Shattuck]
Email message for LeeAnn Pelham
Subj: "From Values to Compliance: Bridging the Gap, or a Bridge Too Far?"
Dear Ms. Pelham,
I would like to call attention to a big hole that I think exists relative to trying to bridge the gap that is referred to by your above presentation at the Ethics & Compliance Officer Association annual conference later this month.
This hole is that I believe that ethics and compliance professionals have not given adequate consideration to the matter of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous other parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, various academics, plaintiffs' lawyers, and consumer protection organizations.
My further belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope you will talk about the foregoing "hole" in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Next-generation Governance: Integrating the Parts...Seeing Things Whole"
William Bojan, Founder and CEO, Integrated Governance Solutions
From: RDShatt@aol.com
To: info@integratedgovernance.com
Sent: 9/9/2011 8:02:59 A.M. Central Daylight Time
Subj: For Mr. William Bojan
Subj: "Next-generation Governance: Integrating the Parts...Seeing Things Whole"
Dear Mr. Bojan,
I am interested in what your ideas about "next-generation governance" are that you will present in your above speech at the Ethics & Compliance Officer Association annual conference..
In terms of "integrating the parts" and "seeing things whole," I would be particularly interested in what you think about the "part" that consists of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My further belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope you will talk about this "part" of corporate governance in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Aligning Policy Management with Your Ethics and Compliance Program"
Doris Balderrama, Director, Business Ethics and Compliance, Starbucks Coffee Company; Neil Moir, Manager, Business Ethics and Compliance, Starbucks Coffee Company; and Barbara Moretti, Internal Policy Manager, Business Ethics and Compliance, StarbucksCoffee Company
From: RDShatt@aol.com
To: businessconduct@starbucks.com
Sent: 9/9/2011 9:22:14 A.M. Central Daylight TimeSubj: For Ms. Balderrama, Mr. Moir, and Ms. Moretti
Subj: "Aligning Policy Management with Your Ethics and Compliance Program"
Dear Ms. Balderrama, Mr. Moir, and Ms. Moretti,
I am a little unclear about what "policy management" (whose policy? whose management?) is being referred to in your above presentation at the Ethics & Compliance Officer Association annual conference later this month.
I wish to suggest that corporate management is not aligned with an ethics and compliance program in one extremely important respect.
This is regarding the matter of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing, and whether corporate management, on the one hand, and ethics and compliance officers, on the other, are likely, in the end, to have differing views about the same.
I believe this is a complex subject that likely entails significant countervailing considerations. Also, other parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, various academics, plaintiffs' lawyers, and consumer protection organizations.
My further belief is that the foregoing parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope you will discuss in your ECOA speech whether there is non-alignment between corporate management and an ethics and compliance program in the foregoing regard.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"What Difference Does Your Program Make?"
Skip Lowney, Senior Project Manager, Ethics Resource Center; and Matt Robbins, Project Manager and Researcher, Ethics Resource Center
From: RDShatt@aol.com
To: ethics@ethics.org
Sent: 9/10/2011 7:39:58 A.M. Central Daylight Time
Subj: For Mr. Lowney and Mr. Robbins
Subj: "What Difference Does Your Program Make?"
Dear Mr. Lowney and Mr. Robbins,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I offer the following for your consideration as a factor relative to an ethics and compliance program making a difference.
Please consider whether entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing is a factor concerning the difference that an ethics and compliance program can make..
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My further belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope you will talk about this factor in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Operationalizing Your Ethics and Compliance Framework: Making Compliance Standards Standard Practice"
J.P. Shotwell, Director and Deputy Ethics & Compliance Officer, Southern California Edison Company; and Lupe Clapp, Manager, Executive Compensation & HR Compliance, Southern California Edison Company
From: RDShatt@aol.com
To: j.p.shotwell@SCE.com
Sent: 9/10/2011 7:59:26 A.M. Central Daylight Time
Subj: "Operationalizing Your Ethics and Compliance Framework: Making Compliance Standards Standard Practice"
Dear Mr. Shotwell,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask you what difference you think entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing has in the operationalizing of an ethics and compliance framework and making compliance standards standard practice.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope you will talk about this matter in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Program Planning and Evaluation: Risk Assessment at Its Best"
Jacqueline E. Brevard, Retired Vice President and ChiefEthics Officer, Merck & Co., Inc.; Trav Ichinose, Principal,Ichinose & Associates; and Bob Olson, Director, MemberServices and Education, ECOA
From: RDShatt@aol.com
To: Jacqueline_Brevard@merck.com, bolson@theecoa.org
Sent: 9/10/2011 9:00:19 A.M. Central Daylight Time
Subj: "Program Planning and Evaluation: Risk Assessment at Its Best"
Dear Ms. Brevard, Mr. Ichinose, and Mr. Olson (I don't have email address for Mr. Ichinose),
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask you what relevance you think entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing has in ethics and compliance program planning and risk assessment. .
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope you will talk about this matter in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Program Evolution and Improvement: The Intersection of Theory and Practice"
Andrea Falcione, Vice President, Advisory Services andChief Ethics Officer, SAI Global, Ltd.; Colin Campbell,Global Head GRC Product Management, SAI Global, Ltd.;and David Karas, Vice President, Ethics and BusinessConduct, Hitachi Data Systems
From: RDShatt@aol.com
To: info.americas@saiglobal.com, info@hds.com
Sent: 9/10/2011 9:42:44 A.M. Central Daylight Time
Subj: For Andrea Falcione and Colin Campbell (SAI) and David Karas (Hitachi)
Subj: "Program Evolution and Improvement: The Intersection of Theory and Practice"
Dear Ms. Falcione and Mr. Campbell, and Mr. Karas,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask you whether ethics and compliance programs could be improved if the law provided for more individual officer and employee liability (as opposed to entity level liability) as means for deterring corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope you will talk about this matter in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"The Dodd-Frank Act: Update on Whistleblowing and Anti-Retaliation"
Bradley L. Ottinger, of Counsel, Baker, Donelson, Bearman, Caldwell & Berkowitz, PC; and Rob DelPriore, Shareholder, Baker, Donelson, Bearman, Caldwell & Berkowitz, PC
From: RDShatt@aol.com
To: bottinger@bakerdonelson.com, rdelpriore@bakerdonelson.com
Sent: 9/10/2011 11:28:59 A.M. Central Daylight Time
Subj: "The Dodd-Frank Act: Update on Whistleblowing and Anti-Retaliation"
Dear Mr. Ottinger and Mr. DelPriore,
I am writing you relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference,
Whistleblowing is highly contentious as a tool to deter corporate wrongdoing. The SEC's proposed regulations under Dodd-Frank received hundreds of comments, many concerning whether a whistleblower should be allowed to bypass a corporation's internal compliance programs. (http://www.sec.gov/comments/s7-33-10/s73310.shtml). Many commenters on behalf of corporate management, and also ethics and compliance professionals, were opposed to the SEC allowing whistleblowers to bypass the corporation's internal compliance programs.
I too submitted a comment to the SEC (http://www.sec.gov/comments/s7-33-10/s73310-252.htm). In my comment, I made the following basic contention:
It is submitted that (i) in dealing with corporate wrongdoing, the law is unacceptably deficient from a deterrence standpoint in the way the law fails to punish officers, employees and other individuals who participate in and are responsible for the design, implementation, and carrying out of corporate acts that comprise corporate wrongdoing, (ii) the law is mistaken in its willingness to assume punishment of a corporation can achieve adequate deterrence, and (iii) the law fosters a mindset and a willingness of some persons to take advantage of the foregoing deficiencies and to benefit from them at the expense of innocent parties, such as shareholders . Until these deficiencies are addressed by lawmakers, regulators, judges and others, there will be similar deficiencies connected with the whistleblower program, the program will fall short in achieving deterrent objectives, and the program will be at risk of being unduly exploited for personal gain and benefit in a fashion similar to that referred to in the preceding sentence.The subject of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing is a complex subject that, similar to whistleblowing, entails countervailing considerations. The numerous parties who have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations, may have very differing views on the subject..
Accordingly, lawmakers, regulators and others should first correct the foregoing deficiencies in the law before the proposed whistleblower program is put in place.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing..
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Reflections of an Ethics and Compliance Officer, Still Learning After All These Years"
Jeff Benjamin, Vice President, General Counsel Litigation, Chair, Ethics & Compliance Audit Committee, Novartis AG
From: RDShatt@aol.com
To: corporatecitizenship@novartis.com
Sent: 9/17/2011 4:33:58 P.M. Central Daylight Time
Subj: For Mr. Jeff Benjamin, Chair, Ethics & Compliance Committee
Re: "Reflections of an Ethics and Compliance Officer, Still Learning After All These Years"
Dear Mr. Benjamin,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask what you have learned after all these years about entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope in your ECOA speech you will talk about what you have learned about this subject.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Cleaning House on Policies and Procedures: Building a System for Enabling Compliance"
Janaize Markland, Compliance & Ethics Manager, Pacific Gas and Electric Company
From: RDShatt@aol.com
To: invrel@pge-corp.com
Sent: 9/17/2011 4:48:22 P.M. Central Daylight Time
Subj: For Ms. Janaize Markland, Compliance & Ethics Manager
Re: "Cleaning House on Policies and Procedures: Building a System for Enabling Compliance"
Dear Ms. Markland,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask, for purposes of building a system of enabling compliance, whether consideration needs to be given to entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing and obtaining compliance.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope in your ECOA speech you will talk about this subject.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Learnings from a Dialogue on Business Ethics between Today’s Experts and Tomorrow’s Business Leaders"
John O’Byrne, Director, Manhattanville College Center for Ethics; and Deborah Haraldson, Ethics Counsel, MasterCard Worldwide
[Form of email to Mr. O'Byrne and Ms. Haraldson]
Re: "Learnings from a Dialogue on Business Ethics between Today’s Experts and Tomorrow’s Business Leaders"
Dear___________,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to call your attention to this project I have initiated that seeks to foster dialogue between ethics experts and business leaders on the subject of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope in your ECOA speech you will mention my project.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"New Research in Ethics & Compliance: Academicians Weigh In on Effectiveness"
John Dienhart, Professor, Seattle University; and Scott Reynolds, Associate Professor of Business Ethics, Helen Moore Gerhardt Faculty Fellow, Foster School of Business, University of Washington
From: RDShatt@aol.com
To: dienharj@seattleu.edu, heyscott@u.washington.edu
Sent: 9/17/2011 5:51:32 P.M. Central Daylight Time
Subj: "New Research in Ethics & Compliance: Academicians Weigh In on Effectiveness"
Dear Professors Dienhart and Reynolds,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask you what new research there is on the effectiveness of entity level liability versus individual officer and employee liability as means for deterring corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope in your ECOA speech you report on any new research on the subject.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Decisions, Decisions: Which Ethical Decision Model Works for Me?"
Roz Bliss, Corporate Administrator for Ethics and Business Conduct, Northrop Grumman Corporation
From: RDShatt@aol.com
To: courtney.wallize@ngc.com
Sent: 9/18/2011 9:21:15 A.M. Central Daylight Time
Subj: For Roz Bliss, Corporate Administrator for Ethics and Business Conduct
[Ms. Wallize, I cannot find an email address for Ms. Roz Bliss. Would you mind forwarding this email to her or providing me with her email address? Thank you.]
Re: "Decisions, Decisions: Which Ethical Decision Model Works for Me?"
Dear Ms. Bliss,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask whether the existence of external sanctions has a role in your "ethical decision model," and, if so, whether it makes a difference in the model whether the sanctions are in the form of entity level liability versus individual officer and employee liability.
Entity versus individual level liability is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope, if the existence of sanctions has a role in your ethical decision model, you will discuss entity level versus individual level sanctions in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Knowing Your Weak Spots: AssessingLevels of Business Integrity throughout Your
Organization"
Dr. Nicole Dando, Head of Projects, Institute of Business Ethics; and Simon Webley, Research Director, Institute of Business Ethics
From: RDShatt@aol.com
To: info@ibe.org.uk
Sent: 9/18/2011 9:40:03 A.M. Central Daylight Time
Subj: Please forward to Dr. Nicole Dando and Mr. Simon Webley
Re: "Knowing Your Weak Spots: Assessing Levels of Business Integrity throughout Your Organization"
Dear Dr. Dando and Mr. Webley,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask you whether a factor that may contribute to a "weak spot" is whether there is entity level liability or individual officer and employee liability for the deterrence of corporate wrongdoing.
This is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope in your ECOA speech you will discuss whether a factor that may contribute to a "weak spot" is whether there is entity level or individual liability.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Built to Last: Developing a Best-in-Class Code of Conduct"
Maurice Crescenzi, Jr., Global Compliance and Ethics Officer, DeVry, Inc.; and Robert W. Sprague, President & CEO, PCI Communications, Inc.
Re: "Built to Last: Developing a Best-in-Class Code of Conduct"
Dear [Mr. Crescenz][Mr. Sprague]i,
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask whether there needs to be external sanctions to provide support for a "Best-in-Class Code of Conduct" and, if so, whether it makes a difference whether the sanctions are in the form of entity level liability versus individual officer and employee liability.
Entity versus individual level liability is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope, if external sanctions are needed to support a "Best-in-Class Code of Conduct," you will discuss entity level versus individual level sanctions in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
"Blind Spots: Why We Fail to Do What’s Right and What to Do about It"
Max Bazerman, Jesse Isidor Straus Professor of Business Administration, Harvard Business School; and Ann Tenbrunsel, Rex and Alice A. Martin Professor of Business Ethics & Co-director, Institute for Ethical Business Worldwide, University of Notre Dame
From: RDShatt@aol.com
To: mbazerman@hbs.edu, Ann.E.Tenbrunsel.1@nd.edu
Sent: 9/18/2011 10:53:31 A.M. Central Daylight Time
Subj: "Blind Spots: Why We Fail to Do What’s Right and What to Do about It"
Dear Professors Bazerman and Tenbrunsel,Publish Post
Relative to your above upcoming presentation at the Ethics & Compliance Officer Association annual conference, I would like to ask you whether the existence of external sanctions contributes to avoiding "blind spots" and doing what's right, and, if so, whether it makes a difference whether the sanctions are in the form of entity level liability versus individual officer and employee liability.
Entity versus individual level liability is a complex subject that likely entails significant countervailing considerations. Also, numerous parties have or should have an interest in the matter, such as lawmakers, judges, regulators, state attorneys general, criminal prosecutors, corporate management, ethics and compliance officers, various academics, plaintiffs' lawyers, and consumer protection organizations.
My belief is that the interested parties have done an inadequate job in formulating their views on the subject and in communicating with one another about the same.
To try to contribute to remedying this believed deficiency, I have initiated this project to investigate the perspectives, views, analyses, and information the multiple interested parties have concerning the subject of entity level liability versus officer and employee individual liability as a means to deter corporate wrongdoing.
I hope, if external sanctions contribute to avoiding "blind spots" and doing what's right, you will discuss entity level versus individual level sanctions in your ECOA speech.
Not having credentials or formal position in the business ethics field, I have difficulty in getting response to things I say. In the circumstances, I post emails I send in a blog I have in order to create a record by which what I say can be judged. After I send this email, I will post the email here.
Thank you for your attention.
Sincerely,
Rob Shattuck
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