Aristotle said “well begun is half done.” About 2,300 years later, Mary Poppins shared the same advice with her young charges, Jane and Michael. The adage generally is understood to mean that a thoughtful and disciplined start puts a project in a good position for success. With apologies to Aristotle (and Mary), the members of
The research is clear. A good decision with a bad outcome is likely to be viewed – by others and by the decision-makers themselves – as a bad decision in hindsight. Equally so, a bad decision with a good outcome is likely to be viewed as a good decision in hindsight. Both views, however, are
Let’s say you’re a publicly traded manufacturer of a popular medical device, which you sell commercially as well as to a number of VA hospitals. You receive an anonymous internal hotline complaint alleging that certain unauthorized, reverse-engineered components were used in the manufacturing process and that certain quality tests were skipped in the interest of
Too often people argue as though they are in front of a judge, or some other cosmic arbiter of correctness, rather than asking ourselves what might move our opponent. In this edition of OIG Shorts, the Sheppard Mullin Richter & Hampton LLP Organizational Integrity Group explains that to increase our chances of moving our opponent,
Investigations are stressful for an organization’s leadership. But what is often overlooked is that they are stressful for an organization’s employees as well. The need-to-know nature of internal investigations usually restricts knowledge of the investigation’s character, scope, and potential consequences to a relatively small circle of senior management. But the employees who fall within the
At the Global Investigations Review Annual Meeting in New York on September 21, 2023, Principal Associate Deputy Attorney General Marshall Miller (“Miller”) delivered remarks that provide an invaluable glimpse into the Department of Justice’s (“DOJ’s”) current and forthcoming priorities and initiatives on corporate criminal enforcement. Miller’s remarks shed light on various key areas of DOJ’s enforcement
In recent weeks, there has been an uptick in news of cyber-related False Claims Act (“FCA”) activity. For example, on September 1, 2023, the court unsealed a qui tam lawsuit against Penn State University relating to allegations of non-compliance with Department of Defense (“DoD”) cybersecurity obligations. Separately, on September 5, 2023, the Department of Justice
In the 10th edition of the “OIG Shorts” series, Sheppard Mullin’s Organizational Integrity Group continues its exploration of a number of complex compliance matters with a discussion on Setting the Table for Good Decision-Making: And Making Sure the Chief Legal Officer Has a Seat at It. This post discusses why it’s important that Chief Legal
This month, Sheppard Mullin’s Organizational Integrity Group continued its exploration of a number of complex compliance matters as part of their “OIG Shorts” series with a discussion on Understanding the Various Layers of a Targeted Compliance Program. This post discusses the importance of a targeted, multi-layered compliance program focused at individual deals, sales, contracts,
In the first installment of our cybersecurity series, we discussed the importance of developing and implementing practical Information Security policies and procedures within your organization as well as the ethical and legal obligations you have to protect sensitive data within the organization.
