More from the Author

• Case | HBS Case Collection | September 2018 (Revised November 2018)

  An Innovative Anti-bribery Commitment?

  Eugene Soltes

  Reebonz, an online luxury goods platform based in Singapore that operates across the Asia-Pacific region, offers its investors the opportunity to redeem shares if either the firm or its founder are investigated by the U.S. or U.K governments with regard to complying with the Foreign Corrupt Practices Act of 1977 or the U.K. Bribery Act. Readers are asked to consider the merits of this commitment and whether other firms should offer a similar anti-bribery commitment.

  Keywords: Foreign Corrupt Practices Act; United Kingdom Bribery Act; Law; Leadership; Moral Sensibility; Financial Services Industry; Technology Industry; United States; United Kingdom; Asia;

  Citation:

  Soltes, Eugene. "An Innovative Anti-bribery Commitment?" Harvard Business School Case 119-039, September 2018. (Revised November 2018.)  View Details

  CiteView DetailsEducatorsPurchase

  Related

• Case | HBS Case Collection | October 2018

  Learning How to Honnold

  Eugene F. Soltes, Sara Hess and Dutch Leonard

  Alex Honnold is the world’s most accomplished free climber. To many, climbing sheer vertical faces of rock- like the famed El Capitan- without a rope is viewed as not simply risky, but reckless. Honnold contrasts this sentiment by presenting his perspective on risk taking and the challenges of living a fulfilled life.

  Keywords: Risk Management; Goals and Objectives; Personal Development and Career; Perspective;

  Citation:

  Soltes, Eugene F., Sara Hess, and Dutch Leonard. "Learning How to Honnold." Harvard Business School Case 119-043, October 2018.  View Details

  CiteView DetailsEducators

  Related

• Article | NYU Journal of Law & Business

  Evaluating the Effectiveness of Corporate Compliance Programs: Establishing a Model for Prosecutors, Courts, and Firms

  Eugene F. Soltes

  When prosecutors, courts, and regulators make charging and sentencing decisions, they must evaluate whether firms have effective compliance programs. Such evaluations are difficult because of the challenges associated with measuring effectiveness. Notably, these obstacles are not limited to evaluation by external parties, as firm managers also struggle to assess the returns associated with investments in compliance. To address these limitations and to facilitate a more consistent assessment, this article provides a framework to rigorously evaluate the effectiveness of compliance programs. I present empirical models that use data collected from compliance initiatives—including whistleblower hotlines, training exercises, and disciplinary procedures—to evaluate whether the initiatives are fulfilling their desired objectives. By being able to more rigorously evaluate compliance programs with data and empirical analysis, prosecutors and courts will be able to more readily discern “window-dressing,” and firm managers will be able to better understand the efficacy of their investments in compliance.

  Keywords: Corporate Governance; Governance Compliance; Performance Effectiveness; Performance Evaluation;

  Citation:

  Soltes, Eugene F. "Evaluating the Effectiveness of Corporate Compliance Programs: Establishing a Model for Prosecutors, Courts, and Firms." NYU Journal of Law & Business 14, no. 3 (Summer 2018): 965–1011.  View Details

  CiteView Details Read Now

  Related