Bass, Berry & Sims attorney Thad McBride, who heads the firm's international trade group, collaborated with Ernie Edgar, North American general counsel and chief compliance officer for Atkins, to co-author the article "Tone at the Top, Culture of Compliance, and the Yates Memo." The article was the feature article in the January/February 2016 issue of ACC Docket.
In the article, Thad and Ernie underscore the need for companies to create a strong culture of compliance, particularly in light of the Yates Memo and the U.S. government's corresponding emphasis on prosecuting individual wrongdoers. In particular, Thad and Ernie suggest that organizations can develop an effective compliance culture through steps such as the following:
- Prepare and circulate a clear statement of management commitment to compliance bolstered with tangible examples of that commitment.
- Empower senior staff to become compliance champions.
- Embed compliance in business processes.
- Train personnel.
- Engage personnel.
- Reward compliance successes – visibly.
- Penalize compliance mistakes – visibly.
The full article, "Tone at the Top, Culture of Compliance, and the Yates Memo" is available on the ACC Docket website or the PDF below.