text: Ethics: Andrew Fastow - Kansas CityContact Our Team General Registration Date:10/29/2019Start Time:7:30 AMEnd Time:10:00 AMLocation:1900 Building - Parkway RoomAddress:1900 Shawnee Mission ParkwayCity:Mission WoodsState:KansasZip:66205Phone:888.591.3140Email:email@example.com To Calendar Join RubinBrown and guest speaker Andrew Fastow to obtain your two hours of Ethics CE! Andrew Fastow was the Chief Financial Officer of Enron from 1998 to 2001. In 2004, he pled guilty to two counts of securities fraud, and was sentenced to six years in federal prison. Fastow completed his sentence in 2011. Despite today's more rigorous regulations, there continues to be "Enron-esque" failures of corporate governance and compliance. Enron's former CFO will make observations about how the ambiguity and complexity of laws and regulations breeds opportunity for problematic decisions and will discuss what questions corporate directors, management, attorneys, fraud examiners and auditors should ask, in order to ensure that their companies not only follow the rules, but uphold the principles behind them. He will also discuss ways in which technology can be deployed to illuminate such problematic situations. Timing 7:30-8:00 Registration & Breakfast 8:00-10:00 Seminar Continuing Education CPE Credit: 2.0 CLE Credit: 2.0 Field of Study: Business Ethics Meeting Type: Group Live Level of Knowledge: Basic Prerequisites: None Advance Preparation: None Price: No Fee For more information regarding concerns and/or program cancellation policies, please contact our office at firstname.lastname@example.com or call 1.888.591.3140. In order to be awarded the full credit hours, you must be present, registering your attendance and noting late arrival or early departure times on the attendance sheets at the registration desk. Registrations Available:PAST EVENT : Return to Calendar Please note Internet Explorer 8 is no longer supported by Microsoft. If you experience an error while trying to register and are using IE8 or older, please call 888.591.3140 or send your registration information to firstname.lastname@example.com. First Name: * Last Name: * Title: * Company Name: * Company Address: * City: * State: * Zip Code: * Phone: * Email Address: * If you have any issues registering, please call 888.591.3140 or send your registration information to firstname.lastname@example.com.


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I was about to write bestdigital distributor, but I remembered GOG.com and relegated Steam to biggest. It certainly is one of the better modern game digital distributors, of course, what with Valve games being there and nowhere else.
So, getting back to the topic, Steam has uncorked the finely beta-aged wine of Steam Trading and allowed all Steam users access to its digital trading feature. Steam Trading is, very simply, a digital trading service built atop the Steam client that allows users to trade Team Fortress 2, Spiral Knights and Steam Gifts with one another. Valve have also said that trading of items from Portal 2 will soon be open. Steam Gifts can be traded for other games or TF2 and Spiral Knights items as long as you have not opened the gift:-
Any game you've purchased from the store as a gift, or received as an Extra Copy, can be traded to other users. They can be used to trade for other Gifts, or for items in Team Fortress 2 or Spiral Knights
This is quite a lovely step up by Steam and is a boon for many online game trading forums that relied on trust instead of a portal like this for their trading. Of course, you could also stock up a sizable collection of hats from Team Fortress 2 , but that is completely up to you.

subset: commoncrawl


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Baltimore, Md., Nov 11, 2011 / 03:29 am MT (CNA).-
Religious freedom is fundamental to a free society, but some political and cultural trends are threatening that freedom, the Catholic bishops of Maryland said in a new statement.
"Efforts to restrict the rights of individuals and institutions because of their religious or moral beliefs are on the rise here in Maryland and around the nation," the bishops wrote.
"Religious liberty—a right rooted in our human dignity and protected by the First Amendment to the U.S. Constitution—is being silently and subtly eroded."
The 12-page document, titled "The Most Sacred of all Property: Religious Freedom and the People of Maryland," was signed by Cardinal Donald W. Wuerl, Archbishop of Washington; Archbishop Edwin O'Brien, the apostolic administrator of Baltimore, and Bishop W. Francis Malooly of Wilmington.
The document took its title from American Founding Father James Madison, who called conscience "the most sacred of all property" and its exercise "a natural and unalienable right."
Religious liberty is a "foundational element of a vibrant democracy" that helps guarantee other freedoms, the bishops underscored.
"The only way to preserve it is through the vigilance of concerned citizens and their willingness to stand up for this right."
While Americans presently enjoy many freedoms, there has recently been a "subtle promotion" of the idea that religious freedom should be restricted only to Sunday worship.
"The right to exercise our faith and follow our conscience in all aspects of our lives is a right increasingly viewed with hostility."
Health care professionals have come under pressure to perform abortions or distribute drugs that violate their pro-life principles, the bishops noted. The Department of Health and Human Services' mandate requiring health plans to cover contraception and sterilization is another example of this threat.
The 600 Catholic hospitals in the United States are coming under increased scrutiny for "providing care in accordance with their—our—religious beliefs." The American Civil Liberties Union has also asked the federal government to investigate Catholic hospitals for declining to provide abortion and emergency contraception, alleging that the hospitals are violating federal law.
On the efforts to redefine marriage, the bishops said that these initiatives put at risk the religious liberties of individuals and institutions that acknowledge heterosexual marriage "not only as a fact of nature but also as an article of faith."
Legislation in Maryland to recognize same-sex "marriage," which failed to pass in 2011, would have done "grave harm" to religious liberty because it provided no protections to individuals and only limited protections to institutions to allow them to maintain their "sincerely held beliefs about marriage."
Religious business owners such as florists, bakers, musicians or photographers would not have been able to decline to participate in a same-sex "marriage" ceremony.
After the District of Columbia passed a law recognizing same-sex "marriages," the district government told the Archdiocese of Washington's Catholic Charities that it could not continue its 80-year-old partnership in adoption and foster care services because the archdiocese would place children in homes only with a mother and a father.
The Maryland bishops also warned of a "growing trend of government intrusion into the institutional and administrative life of the Church."
Proposed Connecticut legislation in 2009 provided "one of the most alarming" examples of this trend.
The legislation would have allowed the state government to mandate the structure and organization of Catholic parishes. It also would have removed many administrative and pastoral responsibilities from the pastor and placed them in the hands of committees defined by the legislature.
The bishops' statement hearkened back to the Maryland colony's Toleration Act of 1649, the first American law to protect religious freedom. The bishops recounted how this practice ended only decades later when the colony was placed under royal control and the Church of England became the established religion.
This history teaches that religious liberty requires "constant vigilance and protection, or it will disappear."
The bishops stressed that prayer and education are needed to counter threats to religious liberty and gave the faithful practical suggestions, noting that Catholics should first thank God for religious liberty.
They should also pray for elected leaders and public officials whose actions affect religious freedom, and for those who disdain or do not appreciate that freedom, the bishops said.
The Catholic community must also stay informed about threats to religious liberty through media like diocesan newspapers. The bishops advised readers of their document to share it with others.
Political action is also necessary to defend religious liberty, they said. Maryland Catholics should vote in every election. They should register with the Maryland Catholic Conference's Catholic Advocacy network and participate in religious liberty events like Catholic Lobby Night held in Annapolis every President's Day.
"Everyone has the right to live in accordance with his or her particular religious beliefs, subject only to such limits as are necessary for the safe operation of society," they said. "Society as a whole benefits when all citizens in our pluralistic democracy—including religious citizens and institutions—remain free to participate in public life and to do so in accordance with their sincerely held beliefs."
Religious freedom upholds human dignity and is integral to the establishment of a good and just society, the statement said. It invoked religious groups' work to abolish slavery, work with the mentally or physically disabled, and religious involvement in labor rights.
The document referenced the work of the civil rights movement, which made an "explicitly religious call" for equal treatment for African Americans. The bishops cited Rev. Martin Luther King, Jr.'s description of churches as "the conscience of the state."
"Rev. King's message of equality and justice thus presupposed and deliberately relied upon a free and flourishing religious tradition to bring about its noble goals," they said.
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New tools aid volcanic ash monitoring
While satellites are providing an ideal way of monitoring the cloud of volcanic ash sweeping across much of Europe recently, a ground-based network of lidar instruments has also been providing a valuable source of information to help meteorologists assess this unprecedented event.
The Earlinet network of lidar stations has been closely monitoring the cloud of volcanic ash from the Eyjafjallajoekull volcano in Iceland since it started erupting on 15 April. The network, which comprises 26 different stations across Europe, uses lidar, short for 'light detection and ranging', instruments that shoot powerful bursts of light from a laser into the sky to acquire information on the physical properties of the atmosphere.
As the light travels through the atmosphere, it interacts with molecules of gas, droplets of water and particles of dust or ash. Since some of the light is 'backscattered' to the instrument on the ground, it is possible to work out the distance of the 'scatterers' by differencing the time between sending and receiving the light. This method offers an excellent opportunity to monitor particles of airborne ash from the ground.
ESA's General Studies Programme is currently funding Earlinet to establish a database of atmospheric profiles that show the presence of clouds and aerosols to support two of the Agency's Earth Explorer missions currently in preparation. The two missions, ADM-Aeolus and EarthCARE, will both carry lidar instruments to advance our understanding of the atmosphere from space.
ADM-Aeolus will be the first space mission to directly measure wind profiles on a global scale and EarthCARE will acquire vertical profiles of clouds and aerosols to improve our understanding of the role they play in climate regulation.
With air traffic paralysed in the last days as the huge plume of volcanic ash drifted across much of European, the Earlinet network was able to make a significant contribution to the monitoring the situation by validating meteorological model simulations that were subsequently being provided to the Volcanic Ash Advisory Centres.
The data collected by Earlinet comes in form of profiles, which clearly showed depth and density of the cloud of volcanic ash. Data from NASA's Calipso mission, the only Earth observation mission currently in orbit that carries a lidar, also contributes to these datasets.
In addition, measurements taken from the DLR German Aerospace Center's Dassault Falcon 20E research aircraft, which carries a downward looking lidar, were also incorporated into the network's data.
The cloud of volcanic ash created an unprecedented situation with European air traffic being grounded for almost a week – a situation that required a collaborative approach between various institutes and agencies to provide accurate information to the decision makers. Moreover, the opportunities that the ground-based lidar network offers are expected to be exploited further in the future.
For further information please contact:
Paul Ingmann
ESA Earth Observation Mission Science Division
Tel: +31 71 565 4459
Email: paul.ingmann @ esa.int
Andrés Gálvez
ESA General Studies Programme Manager
Tel: +33 1 5369 7623
Email: andres.galvez @ esa.int


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RIANZ claimed a total of $2669.25 in penalties. This was made up as follows:
The cost of the music was calculated as being five tracks (total number of notices) multiplied by the $2.39 cost of each track on the iTunes store. The observant may notice that this works out to $11.95 rather than $1075.50. RIANZ decided, based on some self-serving research, that each track had probably been downloaded 90 times and therefore the cost should be multipled by 90. There is no basis in the Copyright Act or Tribunal regulations for this claim.
- $1075.50 as the cost of the music.
- $373.75 to repay the cost of the notices and tribunal fee.
- $1250 as a deterrent.
When we met the defendant she was very worried about the case and what it would mean for her. It caused her significant distress and preparing a defence interrupted both her studies and her part time job. The thought of a $2669 penalty weighed heavily on her and her plans for the future.
She immediately cancelled the flat's internet account and her and her flatmates were from that point without an internet connection at home. Obviously this was not good for their studies, social lives or personal business (e.g. online banking).
The flatmates refused to acknowledge any responsibility or offer to pay any money towards the penalty. Relationships in the flat broke down and the defendant left the flat soon after.
Read the rest of the article in the link.


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Elle's Joe Zee Reveals Exactly What a Magazine Creative Director Does
As creative director for Elle, Joe Zee describes his as an "interesting, sort of nebulous title."
"I work with all the visuals from cover to cover, so when you read the magazine, whether it's the model, the celebrity, the styling, the fashion, the photography, all those things come into my play," Zee explained in our Media Beat interview. "It's really sort of helping to define a visual signature for the magazine."
And @mrjoezee gets pummeled with questions daily from women trying to mimic the seemingly effortless style of their favorite celebs. The number one question he gets? No, not that white pants after Labor Day thing — seriously, are we still discussing that?
"I think the biggest question I get all the time is people want my job. How do I do what you do?" said Zee. "I love my job, and it definitely is glamorous after all these years. But there was a lot of years of no glamour to get to that point."
Part 1: Elle's Joe Zee Puts It All on the Line for Sundance Channel
Part 3: How Elle's Joe Zee Broke Into Fashion (and How You Can Too)


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Last night's event
Thanks to all of you who came out last night. I hope you agree, but I thought the shows were really great and definitely showcased some of the fantastic programming that FSN Prime Ticket is providing the fans. Having Luis, Raffy, Manny, Ned, Dave Jauss and others there also seemed to make the event even more special.
For those of you who got to chat with those guys, you realize just how down to Earth they both are and Tony Jackson's story in today's Daily News definitely shows that side of Luis. I can definitely attest to the fact that he's among the best people I've ever met, inside or outside of baseball.
And for the person who mentioned how much they liked the game notes, you can actually sign up to get them from MLB's Press Pass. It's free and there's a ton of info you can get by signing up.
Don't forget about De Jon's Waton's chat today at 2 p.m. PT
Lineups to come later in the day.
13 Comments
Fantastic event. Glad this could be made open to some fans…def. a highlight of my season so far.
Josh, thank you for opening this special event to fans. I had a wonderful time.
Thanks for the opportunity Josh. Really had a great time putting back those free Coronas and all that food. Meeting Colletti, Mota and Gonzo was ******* awesome. After I shook Colletti's hand his wife says to me "Did you bring a camera?" Even though I didn't get the picture it was great to meet all those fellas.
I must say, Roger's aim was off last night. Some poor soul got tagged in the head with a bag of nuts. (You know who you are buddy.)
I was, however, a little dissapointed to see that my buddy and I were among a slim few sporting Blue. I only saw a couple other jersies there but not one hat other than ours. To make matters worse, some random dude was wearing a Cardinals shirt…..
Mota was a hungry dude, he hit that buffet at least five times!
Thanks Josh.
Thank you to all who organized this great event for the fans. It was a true thrill to be up close and personal with the players and members of the organization. Thank you again and I can't wait until next time.
Thanks so much to Josh and everyone else with the Dodgers and Prime Ticket who put this amazing event together. It was a fantastic evening I'll never forget! Much appreciated!
nkirby4 "After I shook Colletti's hand his wife says to me "Did you bring a camera?" Even though I didn't get the picture it was great to meet all those fellas."
on the E-Mail I got it said to "please not bring in cameras" but I guess it was more "lax" once your in the event. I got there a little late but just in time for the premire it was a really nice showing & again Josh thank you very much.
Hey nkirby4 – "Some poor soul got tagged in the head with a bag of nuts. (You know who you are buddy.)"
Ya, I know who that "poor soul" was! The look on Roger's face was priceless! He looked like **** Cheney on that ill-fated hunting trip. Even though I assured him that it didn't hurt at all, he spent a good five minutes apologizing to me. I think I rattled him a little when I told him that he'd be hearing from my attorney – LOL.
Thanks for letting me hang with you guys. Just remind me to never get into a beer slamming contest with you guys! What a great time it was.
Man I knew I was gonna regret blowing off the event …. Pulled a groin muscle yesterday at work and my wife was swamped at work…Free coronas would have made the strain hurt less.Even missed out on Peanut tag….Nobody mentioned free food and beer…I'm just one sorry fan I guess…..
What a great night! The Peanut Man came over and told us stories, we ragged on Ned Colletti for sending down Loney, ate our fill of finger food and drink, sat next to Larry Stewart of the Times in the Zanuck Theater, and generally felt like the in-crowd all evening. Thanks, and let's do it again, soon!
Same here fisher i would have rather been there with all you who went enjoying a Corona and some good food(it sounds like it anyway) instead i had a business meeting to attend! O well maybe next time.
Great, great event. Thank you for the opportunity Josh…. The gift bags at the end of the evening were a nice touch! Arriba Los Doyers!!
Josh: "And for the person who mentioned how much they liked the game notes, you can actually sign up to get them from MLB's Press Pass. It's free and there's a ton of info you can get by signing up."
Thanks for the tip! I will look into it!
Sounds like a great time had by all. If a similar offer comes along again, you can bet there will be no hesitation on the part of your readers to sign up!


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Anti-sleeping sickness drives may also need to target animals
Trying to eliminate the main form of sleeping sickness in Africa by only targeting humans may end in failure as the disease would soon return from its animal reservoir, according to a study published today (17 January).
Sleeping sickness is a deadly disease caused by Trypanosoma parasites transmitted by tsetse fly bites. It affects up to 30,000 people a year in 36 countries in Sub-Saharan Africa, where there are two variants of the disease.
The east African type is known to also infect cattle and wild species, but the west African variant that accounts for more than 95 per cent of human cases is believed to persist mainly because of human-to-human transmission.
- Animals could be vital hosts of the tsetse fly-transmitted sleeping sickness parasite
- Efforts to eradicate the disease must focus on animal reservoirs as well as human infections
- But some disease hotspots have been eliminated without targeting animals, says expert
Now, a modelling study in PLOS Computational Biology challenges the notion that the parasites, Trypanosoma brucei gambiense, do not spread in animal populations in the absence of human infection.
Researchers used human and animal case data from two screening campaigns conducted in 1998-1999 in Cameroon — one of the few efforts to link the presence of the parasite in different animal species to human cases.
They found that, if the disease were eliminated from humans, it would take less than a year for it to be reintroduced if more than one tsetse fly in every 1,000 switched between animal and human hosts. They added that this is realistic as flies are unlikely to restrict themselves to just one host.
Sebastian Funk, lead author of the study and a researcher at Princeton University, United States, says that the study shows the usual method of eliminating the disease — by treating infected patients with drugs — is insufficient.
"The main message of this study is that we need to keep the animal reservoir in mind and it's not enough just to focus on humans," he tells SciDev.Net.
Funk says that human case control "has worked very well", but that "there's a risk of the disease coming back" if elimination efforts focus just on that.
The study also raises an "intriguing hypothesis" that the decline from a high of around 40,000 reported cases of sleeping sickness in 1998 might have been driven by the wildlife habitat loss.
"The reduction in wildlife habitats could play a role in the reduction of sleeping sickness," says Funk, although he adds that the paper did not examine this link systematically.
But Pere Simarro, head of the human African trypanosomiasis programme at WHO, is sceptical.
He says the finding about the animal cycle's role in the disease is not "strongly supported" by evidence in the paper.
"There are several examples where [the west African] sleeping sickness foci have been eliminated without taking the animal reservoir into account," he says. "Other factors have a crucial role in sleeping sickness transmission other than the animal reservoir, such as land use, demography, climate change and economic development."
Link to paper in PLOS Computational Biology
You might also like
- Spraying cattle with insecticides 'cuts sleeping sickness'
- Sleeping sickness drug resistance mechanism identified
- Neglected diseases should share diagnostic tools
- Sleeping sickness drug 'a step closer to reality'
- Livestock trade is culprit in sleeping sickness spread
- Sleeping sickness parasite has a weak spot in its tail
PLOS Computational Biology doi: 10.1371/journal.pcbi.1002855 (2012)


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I am on Ubuntu 12.04. As I was working icons on the top bar started disappearing. I tried to switch between the various windows but Alt + Tab was not working. I tried using the mouse to switch between windows but to no avail. On rebooting, the screen stops at
*Checking battery state. insmod: can't read `/usr/local/bin/ztemtApp/ztemtusbserial/ztemt.ko'. No such file or directory.
Output of /var/log/syslog is http://paste.org/59250
I tried the answers given here Boot hangs after "Checking battery state..." .But that doesn't work. I reconfigured lightdm and restarted but that also did not work. Could someone please help me out?


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Dec 20, 2012
There was wine involved in the hatching of this idea. So it's only fitting that this film was paired with a little bit of cheese. What can I say? I'm a softie for this dog. Here's a picture from the wrap party with our enormous cast and crew. Looking forward to working with this talented actress again even if she is a little bitch.
5 responses to "Stella's Xmas Adventure"
Great film… Our 'Lucy' couldn't get enough of it! Hope you are having a great holiday.
Hi Stela – My name is Jen and I am the mom to a 3-1/2 y/o Boston named Lelu. We have enjoyed watching your adventures. We have just found your videos. Looking forward to more of them.
Blessings and Boston kisses
~Jen & Lelu~
From Sequim, WA
Brilliantly done. I am working with Brian Rueb and he sent me the link to your work. Had to say props to you on this one. Love the feel. perhaps we will be talking soon enough. Take care.
That was great. You are a very talented dude;)
Aw shucks … this just about had me in tears !!! It just amazes me how you get such great shots of Stella running, riding, "posing" … GREAT movie !!!


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The modern Festival is intended primarily for amateurs - defined as people who do not earn their living from the branch of performance in which they wish to compete. Some classes such as the Singing Gold Medal remain Open (for entry by anyone) with the aim of attracting young professionals to perform and maintain high standards. Entrants can be as young as 4 years old, and others continue to compete until well into older age.!
All entries this year will be on line.


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This thick, cheesy dip is delicious with broccoli spears or bread sticks, or even as a spread on slices of bread. Serve any leftovers on baked potatoes or tossed with potato salad.
- Yield
- Makes 3 1/2 cups
- 4 cups broccoli florets (10 ounces), cut into 1 1/2-inch pieces
- 3 scallions (white and green parts), trimmed and cut into 1/2-inch pieces (about 3/4 cup)
- 1 small garlic clove
- 10 ounces sharp Cheddar cheese, room temperature, cut into 3/4-inch cubes (about 2 cups)
- 4 ounces cream cheese, room temperature
- 1 cup plain whole or lowfat yogurt
- 1/4 teaspoon freshly ground black pepper
- 4 ounces bread sticks or pretzels, for serving
- In large saucepan of boiling water, cook broccoli 1 minute. Immediately drain and rinse under cold water to stop cooking. Pat dry. Transfer half of broccoli to covered container and refrigerate until ready to serve. Transfer other half to food processor and add scallions and garlic. Pulse until finely chopped, about 10 (1-second) pulses. Transfer mixture to medium bowl.
- In same processor, combine Cheddar and cream cheese and process until smooth, about 3 minutes. Return broccoli mixture to processor, add yogurt and pepper, and pulse until blended, about 15 (1-second) pulses. Transfer to large covered container and refrigerate until ready to serve. Serve dip with reserved broccoli florets and bread sticks or pretzels.
- Transportation tips:
- For simple, elegant, cooler-to-blanket serving, refrigerate the dip in a sturdy glass bowl with a lid, such as those made by Pyrex. If you'll be serving it to a large group, use two bowls for easy passing. Transport pretzels or breadsticks in their packaging and then place them in bowl at the picnic site, or transfer them at home to a Tupperware container and use that as a serving dish as well.


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Guarding Against Fraud and Corruption: The Audit Committee's Role
Imagine two similar companies that are publicly alleged to have engaged in a significant incident of fraud or corruption, such as bribery of foreign officials. Company A takes a proactive approach to managing fraud and corruption risks, has worldclass—but not infallible—antifraud and anticorruption processes, has a good relationship and strong record with its regulators, and has robust plans in place to investigate potential wrongdoing and to implement crisis communications to help protect the company's reputation.
Company B takes a reactive approach, is confident in its ability to deal with issues as they arise and is a follower rather than a leader in implementing risk management and antifraud and anticorruption processes.
As an investor, which company would you believe better protects your investment? From an audit committee member's perspective, which company would you judge better able to demonstrate that you have fulfilled your duty of care as a director?
Of course, there is no guarantee that a better-prepared company will experience a more favorable outcome than one that chooses a reactive approach. But experience suggests that companies that manage their risks proactively may be less vulnerable to having their reputations harmed by allegations of wrongdoing, falling behind in the news cycle of reactions and losing the support of regulators, customers, suppliers, investors, the general public and even politicians.
Global media and the Internet enable news to travel faster and reach more people than ever before. The international nature of business and growing collaboration among regulators worldwide can expose companies to a greater number of regulatory regimes. These factors may increase both the likelihood and the potential impact of alleged wrongdoing on a company's reputation and shareholder value. Audit committee members may want to consider how their company manages its risks of fraud and corruption and whether today's risk environment merits a more proactive approach.
10 Areas the Audit Committee Can Evaluate to Help Mitigate Reputational Risks of Fraud and Corruption
There are many ways the audit committee, assisted by internal auditors or advisers, can seek to help management and the board of directors mitigate reputational risks that could arise from alleged fraud, bribery or corruption. Outlined below are 10 items that can help the audit committee gauge the company's sophistication in this area and assess the scope for improvement.
1. Integrating Risk and Strategy
When risks and rewards are considered separately, it may be easier for those pursuing growth to omit or diminish consideration of reputation and compliance risks. Holding senior and operating management responsible for considering risks and balancing them with potential rewards can foster wise risk-taking. Does management consider risks in developing and implementing the company's strategies and business plans?
2. Crisis Management Planning
Has the company developed a crisis-management plan to react to allegations of major fraud or corruption? Does that plan include assigned responsibilities for management and advisers to help drive actions and communications that will sustain confidence? These plans can be valuable in implementing a robust response to allegations under severe time pressure and intense scrutiny from the media, regulators, investors and law enforcement.
3. Comprehensive Risk Assessment
Risk assessment is the foundation on which effective antifraud and anticorruption processes are built. Does management conduct, document and update an assessment of fraud and corruption risks periodically (typically annually)? Can management explain key fraud and corruption risks that may affect the company's reputation?
4. Risk Tolerance and Mitigation Planning
Does the board understand management's level of overall risk tolerance and its level of risk tolerance for fraud and corruption specifically? Has the board determined its level of risk tolerance for these matters? Having the board determine risk tolerance is not easy, and the practice is not yet widespread, but if the board has done so, to what extent does it correspond to management's level? Are efforts to mitigate these risks designed to bring them within the risk tolerance level? Incidents of major fraud and corruption may indicate a gap between the risk tolerance level of the board and that of management, or between that of executive management and line personnel.
5. Managing Performance and Compensation
Is effective risk management an explicit element of performance assessment and compensation for executives and managers? Holding senior executives and line management accountable for managing ethics, compliance and the fraud and corruption risks within their area of responsibility is likely to be more effective when it influences their compensation. This can be evaluated using objective measures, such as the results of an assessment by the internal audit function.
6. Evaluating the Tone at the Top
Does the audit committee evaluate employees' perceptions of the tone at the top periodically (leading practice is annually), using techniques such as an employee survey? A professionally designed and independently administered survey may serve as an early warning system, alerting the audit committee to a tone that falls short of its expectations. See 10 Ways to Measure the Tone at the Top.
7. Whistleblower System Benchmarking
Does the audit committee review an evaluation of the whistleblower system that benchmarks its performance against industry-specific statistics? A benchmarking analysis may help identify an underperforming whistleblower system, enabling remediation. Below-average use most often arises in hotlines that are not effectively communicated to employees and other potential users, or where users lack confidence that reports will be addressed appropriately without retribution.
8. Leveraging Transaction Monitoring and Data Mining
Has the company implemented computer-assisted transaction monitoring and data mining targeted at its key fraud and corruption risks? These tools are especially valuable in entities with a large volume of transactions and potentially high-impact fraud and corruption risks, such as violations of the Foreign Corrupt Practices Act or the U.K. Bribery Act that became enforceable on July 1, 2011. Today's technology, combined with skilled evaluation of anomalies, can enhance deterrence and detection capabilities in this area significantly.
9. Regulatory Relationships
Does the company have a good relationship with regulators, such that regulators may be more supportive if the company has to investigate alleged wrongdoing? Companies of all sizes are vulnerable to additional costs, restrictions on operations or potential shutdown if regulators decide they cannot be trusted to investigate themselves. A cooperative relationship and a strong record with regulators can help avert turning a serious allegation into a regulatory crisis.
10. Investigative Resources and Protocols
Financial investigations often involve locations on the other side of the world, involving a different language, different laws and a different culture. Predetermining investigative resources and protocols can speed an investigation and also help reduce the risk of ineffective investigations. Has the audit committee identified in advance the legal, computer forensics and forensic accounting resources needed to conduct internal investigations into serious allegations that may arise wherever the company operates? Has it approved a set of investigation protocols to help avoid reputational risks that can arise from inappropriate investigation methods? Do the company and its whistleblower system operator have a process to identify the correct parties to notify internally for different types of allegations? Does this process set forth investigation roles and responsibilities depending on the nature
of an allegation?
The Importance of Asking Questions
The audit committee can be valuable in probing management's decisions regarding the appropriate level of sophistication of the processes to help mitigate the reputational and financial risks of alleged fraud, bribery and corruption. Management, the audit committee and the board may have different views on the cost/benefit tradeoffs involved and the appropriate balance given the risk environment. Asking the questions set out above may help better define and mitigate reputational or financial risk in the event of allegations of fraud, bribery or corruption.
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Antitrust Case Filings
Antitrust Case Filings
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View the list of NAICS and SIC industry codes used by the Division. To view all industry codes, visit Census.gov.
Displaying 1 - 1 of 1
|Case Open Date
|Incident Date
|Case Type
|Federal Court
|Industry Code
|U.S. v. Eastman Kodak Co.
|May 20, 1994
|Civil Non-Merger
|Second Circuit
|Photographic Equipment and Supplies