Gare Smith and I recently co-authored an article on corporate social
responsibility ("CSR") and risk management for Executive Counsel magazine. In
the article, "Making Corporate Social Responsibility
Systemic," one issue we discuss is the potential risk to
companies that "claim to have embraced CSR and then simply
point to glossy reports reflecting anecdotal philanthropic
initiatives to demonstrate the degree of their commitment." We
such companies fail to develop the internal policies and
mechanisms necessary to ensure that the correct people, in the
right functional areas, are held accountable for following specific
environmental and social standards. References to good deeds do not
mitigate against the risks associated with lack of internal
commitment and oversight.
We observe that a lack of executive-level oversight with regard
to a company's approach to CSR may leave companies with little
capacity to develop strategic and comprehensive responses to
stakeholder concerns about the social and environmental impacts of
the company's operations.
A copy of the full article is available here (.pdf).
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guide to the subject matter. Specialist advice should be sought
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stimates place the amount of money illegally "laundered" through
United States banks in the hundreds of billions of dollars each year.1
For more than five decades, the U.S. government has attacked money
laundering, in part, through anti-money laundering ("AML") disclosure,
monitoring, and reporting requirements placed on financial institutions.
We recently notified you of the FDIC’s Financial Institution Letter 47-2013 , which urges directors and officers of financial institutions to examine their institutions’ directors and officers (D&O) insurance coverage to ensure adequate protection for themselves as well as their depositors and shareholders.
Comments made by Kara N. Brockmeyer, the Securities Exchange Commission’s chief of the Foreign Corruption Practices Act unit, and Charles E. Duross, deputy chief of the Department of Justice’s FCPA unit, at the recent International Conference on the FCPA suggest that both agencies are increasing their scrutiny of possible FCPA violations for the next year.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Last Friday’s edition of the New York Law Journal features an article in its "Outside Counsel" column authored by Mintz Levin colleagues Andrew Roth and Kim Gold, entitled Cracking Down on Executive Compensation for Not-for-Profits.