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Documenting your E&C Program to U.S. Sentencing Commission

Karen Blum , Sr Director, Ethics and Compliance Management, Apollo Group, Inc. Christina Reese , Director, Ethics & Compliance Services, Apollo Group, Inc. Bill Wise , Senior Counsel, Holland & Knight, LLP Karen & Christina presented at the 2013 Annual Ethics & Compliance...


Blog Entry
Ethics Exchange: Incentives

Jeff Kaplan : As you know, Steve, since the 2004 amendments to the Sentencing Guidelines, incentives have been part of official expectations relating to E&C programs. Indeed, in 2010, in an FCPA case against Alcatel-Lucent, among that company’s violations of the FCPA internal controls...