The Frontlines - An Interview with Jordan Thomas
March 31, 2014
Jordan A. Thomas speaks with Ethisphere magazine about the SEC's whistleblower bounty program and shares insight on compliance efforts
Drawing from his experience within the Division of Enforcement at the SEC, Labaton Sucharow's Jordan Thomas was asked for one or two aspects of a compliance or ethics program most often overlooked by companies.
"As a first responder to corporate scandals, I have come to believe that wrongdoing is rarely caused by "rogue" employees, insufficient compliance resources, inadequate policies and procedures or compliance personnel that lack vigilance—as is commonly thought. In my experience, I have found that big misconduct often results from a long chain of little mistakes; one breakdown in ethical judgment cascading to another breakdown and then another," he said, adding, "Ultimately, I have concluded that the most common cause of significant corporate wrongdoing is that the organizations involved lacked a culture of integrity and discouraged their employees from speaking up. Notwithstanding this fact, too many organizations focus almost exclusively on the mechanics of compliance and the response to misconduct—not establishing a culture of integrity that would deter or prevent misconduct in the first place"
Please click here for the full Q&A.