Executives Acting in Bad Faith and the Role of the Board
“While the Company had a compliance program and a supporting control framework, they were not adequately implemented. Specifically, certain employees in some markets, some of whom were executives in those markets, acted in bad faith and knowingly failed to implement sufficient controls.”
Compliance Metrics For a Board
There is an affirmative duty to ask the tough questions. The Board needs to ask the hard questions and be fully informed of the company’s overall compliance strategy going forward.