Ethics training and compliance

Train Your Employees to Foster & Maintain a Culture of Ethics

Maintaining a code of professional ethics in the anti-fraud profession is not only critical for your practice, but also for self-preservation. In a similar manner, maintaining an effective compliance program is an absolute necessity to protect an organization from various risks, including those of fraud, financial impact, litigation and reputation loss.

Ethics & Code of Conduct training is an effective way to improve employee awareness of your organization’s key values. Our innovative, video-based ethics training program is designed to train your workforce and help your organization comply with Sarbanes-Oxley (SOX), the Federal Sentencing Guidelines (FSGs), Federal Acquisition Regulation (FAR) amendments, and the Dodd-Frank Act.

Before creating a training program, it is important that the trainer to do their homework and research your company’s situation thoroughly. Most employers understand that good employee training is essential for an organization’s success. Training topics may include general skills such as literacy, technical skills, orientation about the organization, as well as programs designed to prevent lawsuits, audits, and fines, such as sexual harassment training, safety training, and ethics training. Let the experienced professionals at the Ingenium Consulting Chicago assists you developing effective ethics training for your organization.

Code of Conduct Investigation

With perhaps discouraging frequency, companies need to conduct investigations into allegations of employee misconduct. The subject matter of these investigations is diverse, encompassing topics such as sexual harassment, discrimination, embezzlement, misuse of a company’s computer system, information posted about a company on a blog, employee theft, workplace violence, rules violations, drug or alcohol use, and numerous other issues. At times, the alleged wrongful conduct involves illegal activity and the appropriate investigators are federal or state law enforcement personnel. On other occasions, the primary focus of the investigative inquiry is on wrongful, but noncriminal conduct implicating well-established company policies and procedures. In both contexts (criminal and noncriminal conduct), there is almost always a risk of potential civil liability. The alleged wrongdoers (the targets of the investigation) may be the most senior directors and officers of the company (consider, for example, the recent Hewlett-Packard investigation) or hourly employees.

A properly conducted investigation—one that is prompt, thorough and impartial—can help defend a company should a lawsuit be filed later. By ensuring a fair investigative process, the organization can also can help build morale and trust among employees.

Conducting workplace investigations is one of the most challenging duties that organization must take on. Workforce demographics are shifting. New laws are constantly popping up. Managers make mistakes because they aren’t properly trained or they’re under pressure to resolve complaints quickly. Employees are more aware of their rights.

This is a situation where the professionals at the Ingenium Consulting Chicago can help. Our seasoned investigators can quickly and efficiently resolve the matter. Please give us a call for a free confidential consultation.

Client confidentiality and trade secret investigations

Brand and trade secret fraud has increased exponentially due to the globalization of our trading markets. Taking steps to protect intellectual property is serious as when an incident occurs it is crucial to have an immediate and attentive response. Taking steps to protect intellectual property is serious as when an incident occurs it is crucial to have an immediate and attentive response.

Gray market and diverted goods are as harmful as brand fraud or counterfeits. They tarnish and dilute your brand while also decreasing the sales of legitimate products. This can harm your relationships with your sales force, manufacturers and business partners. With globalization this issue will continue to increase and we are here to help you resolve this. Today the gray market has extended to online as well as brick and mortar shops.

We investigate trademark infringements, protect brands and handle counterfeit as well as gray market good diversions with the utmost ethical and legal standards so that our results can be utilized during legal proceedings or for actionable intelligence to base strategic and tactical decisions. Call the professionals at the Ingenium Consulting Chicago and we can help you with this most complex and vexing problem.

Foreign Corrupt Practices Act Assessment

Ingenium Investigators assess compliance programs looking for risk indicators

As anti-corruption enforcement is stepped up around the world, international corporations are coming under increasing scrutiny over their business conduct. In the United States, the number of actions brought by the government has increased dramatically since the Securities and Exchange Commission and the Department of Justice made enforcement of the Foreign Corrupt Practices Act (FCPA) a priority.

FCPA

The US Foreign Corrupt Practices Act (FCPA) of 1977 is the most widely enforced anti-corruption law. It is the first to introduce corporate liability, responsibility for third parties and extraterritoriality for corruption offences, meaning companies and persons can be held criminally and civilly responsible for corruption offences committed abroad. The Act also applies to any act by U.S. businesses, foreign corporations trading securities in the U.S., American nationals, citizens, and residents acting in furtherance of a foreign corrupt practice whether or not they are physically present in the U.S. This is considered the nationality principle of the act. Whenever businesses decide to follow the unethical road, there are consequences including high financial penalties. Any individuals that are involved in those activities may face prison time. This act was passed to make it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business.

• Criminal penalties
  • Up to $2 million per violation for companies
  • Up to $250,000 fine and 5 years in prison for individuals
  • Alternative fines equal to twice amount of total profit

• Civil penalties
  • Injunctions against future violations
  • Civil monetary penalties
  • Collateral consequences (e.g., debarment)

A company cannot indemnify an officer, director, employee or consultant for fines assessed in violation of the FCPA and insurance will not cover such fines or penalties.

A sound system of compliance controls is essential in protecting your firm from business, regulatory and reputational risks. A strong compliance function will also become a factor of increasing importance which will define and set a firm apart from its competition.

The Ingenium Consulting Group Chicago creates and implements compliance programs, and conducts internal investigations, assessments and due diligence on potential merger and acquisition targets, joint venture partners and third parties. We also counsel clients on compliance issues that arise from international licensing, sales and marketing and are well-versed in laws that relate to dealing with government officials.

Ingenium has the expertise to assist your organization in establishing effective compliance controls. Ingenium’s Asset Management and Regulatory team includes a group of experienced professionals with diverse backgrounds in the asset management industry. Our mission is to assist asset managers in identifying, assessing, and controlling business, operational, and compliance risk in an efficient and cost-effective manner.