Dewey's Cautionary Tale of Culture and Compliance

The Compliance Strategist

, Corporate Counsel

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What can in-house legal departments learn from the demise of Dewey & LeBoeuf to better inform their selection of outside counsel?

What's being said

  • "Seen through a compliance lens, the story points to an ethical culture and compliance gap in the highest ranks of the now-defunct firm, extending to others down below who assisted in the alleged misconduct."

    An essential role of leadership must be to acquire data on how well individual decision making align with corporate goals and strategy, and design incentives that encourage and reward performance, while enforcing compliance will applicable laws, rules and regulations.

    The challenge for leadership is to design and implement a framework that effectively empowers and engages employees at every level of the organization. Such a framework might look like:

    1) Effective policy management (online library/policy, IT systems, technology, etc.)
    2) Ongoing assessments (people, process, systems & technology)
    3) Performance Scorecards (hard & soft metrics)
    4) Event management and reporting (Failure Modes and Effects Analysis)
    5) Annual certifications to the Code of Conduct (reinforce values)
    6) Enterprise data analytics (talent & workforce analytics, performance-based job descriptions)

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