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Corporate Compliance and Ethics Institute 2014


Speaker(s): Andrew J. Hinton, Ed Petry, Gary F. Giampetruzzi, James R. Turner, Janice L. Innis-Thompson, Jeannie Rhee, Jeffrey M. Kaplan, Jennifer Heller, Jim Nortz, Kathryn S. Reimann, Kathy Rehmer, Maria C. Hermida, Mark Ehrlich, Nora Kurzova, Paul E. McGreal, Seth M. Cohen, Stephen C. King
Recorded on: May. 29, 2014
PLI Program #: 51084

Andy Hinton is the Vice President of Global Ethics and Compliance at Google. In this role, Mr. Hinton leads the company’s efforts to identify and mitigate compliance risk and to nurture and expand upon the company’s core value of “Don’t be evil.”

Mr. Hinton joined Google in November 2006. From 2003 to 2006, Mr. Hinton was the Chief Compliance Officer at two GE Capital financial services businesses. From 1994 to 2003, Mr. Hinton was a federal prosecutor in New York City, focusing on

white-collar crime. From 1989 to 1994, Mr. Hinton was a litigation associate at the New York City law firm of Cravath, Swaine & Moore, where he focused on commercial litigation and white-collar criminal defense.

Mr. Hinton is a 1989 graduate of Fordham School of Law, where he was a member of the Law Review, and a 1982 graduate of Harvard University, where he majored in Economics.

Mr. Hinton lives in Palo Alto, California with his wife, Joy, an accomplished securities lawyer, and their two children, Sarah and Eric.


Jennifer Heller is Vice President, Chief Compliance Officer, and Senior Deputy General Counsel for Comcast Corporation.  In this role, she is responsible for leading the internal processes for promoting and ensuring Comcast’s compliance with laws, regulations, company policies and contracts, including chairing its enterprise-wide Compliance Committee which oversees its compliance risk management and internal complaint reporting programs.  She is also responsible for formulating and implementing Comcast’s policies and procedures, including its Code of Conduct, and making sure they are communicated and trained upon across the company. 

Comcast Corporation is a global media and technology company with two primary businesses, Comcast Cable and NBCUniversal. Comcast Cable is one of the nation’s largest video, high-speed Internet and phone providers to residential customers under the XFINITY brand and also provides these services to businesses. NBCUniversal operates news, entertainment and sports cable networks, the NBC and Telemundo broadcast networks, television production operations, television station groups, Universal Pictures and Universal Parks and Resorts.


Jim Nortz is a nationally recognized expert and thought leader in the field of business ethics and compliance with two decades of experience in assisting complex organizations effectively manage their legal, operational and ethical risks. Prior to joining the Institute for Priority Thinking in October 2013, as its Executive Vice President, Compliance and Ethics Solutions, Jim served as a compliance officer for four multinational corporations where he was responsible for the development, implementation and maintenance of robust business ethics and compliance programs for each of these global enterprises.

Mr. Nortz is a frequent guest lecturer at the University of Rochester’s Simon School of Business, RIT’s Saunders School of Business, St. John Fisher College and Nazareth College and has published numerous professional articles on compliance, ethics and corporate governance issues. Jim writes the monthly business ethics columns for the Association of Corporate Counsel Docket and the Rochester Business Journal. Jim has also published articles in Ethikos, the Ethics and Compliance Officer Association News Letter and was the first featured author on Corporate Compliance Insights – a Website specifically designed to provide a forum for knowledge exchange between compliance experts on important and timely topics in the areas of ethics, compliance, risk and governance.

Jim served on the Board of Directors for the Ethics and Compliance Officers Association (“ECOA”) for eight years and was the lead facilitator of Nazareth College’s 2010 Interdisciplinary Institute for Professional Ethics dialogues with academic and business professionals regarding the root causes of weak ethical cultures in corporations. Jim is currently on the Board of the Rochester Area Business Ethics Foundation. If you have any questions about his presentation or article, you may contact him at 585-260-8960 or by email at jimnortz@gmail.com.


Kathryn S. Reimann is the Chief Compliance Officer and Managing Director for Citibank, N.A., as well as for Citi’s Global Consumer Businesses. In this role, Kathryn leads the Compliance function covering the Bank’s compliance responsibilities, as well as the retail and commercial  banking, credit card, secured and unsecured lending, and other consumer finance and investment businesses that form the Global Consumer Bank.

Kathryn joined Citi in August 2006 from American Express, where she had been Senior Vice President, Chief Compliance & Ethics Officer. Prior to joining American Express in 1998, Kathryn was Senior Vice President, Chief Compliance Officer and a Senior Counsel of Lehman Brothers, Inc. Kathryn began her career as a litigation attorney, initially with the firm of Curtis, Mallet-Prevost, Colt & Mosle and thereafter in the General Counsel’s Office of Dean Witter Reynolds. Previously, she clerked for Associate Justice Stewart G. Pollock of the New Jersey Supreme Court.

A graduate of Princeton University, Kathryn completed her undergraduate degree and thesis with honors at Princeton's Woodrow Wilson School of Public and International Affairs. She received her JD from New York University School of Law.

Kathryn serves on the NYU School of Law Program on Corporate Compliance & Enforcement Advisory Committee and is a member of the American Law Institute.


Maria C. Hermida has served as Citi’s Chief Ethics Officer since 2007. She is responsible for developing, implementing and communicating Citi’s ethical principles and values and integrating the global ethics programs into business strategies.  As Head of Citi’s Global Ethics Office, she develops and implements Citi’s Code of Conduct, oversees internal investigations, and provides ethics advisory services.  She leads a team of dedicated global professionals and works with cross-functional teams in order to promote ethical workplace behavior and business practices across a global workforce. Previously, Ms. Hermida held various positions of increasing responsibility at Citi, including that of General Counsel to Women & Co., a membership service focused on providing financial insights and resources to the women’s market, and Associate General Counsel for Citi’s bank broker/dealer.

Prior to joining Citi, Ms. Hermida was Deputy General Counsel for Royal Alliance Associates, Inc., an independent securities broker/dealer and investment adviser owned by AIG.  During her seven year tenure, she managed the company’s arbitrations, litigations and regulatory matters.  Ms. Hermida began her legal career as a litigation associate with the law firm of Shanley & Fisher.

Ms. Hermida serves on the Board of Directors of the Ethics Research Center and Ethics and Compliance Association.  Since 2000, she has been an arbitrator for the Financial Industry Regulatory Authority (FINRA).  She has also been an adjunct professor at Fordham University School of Law, and is a frequent speaker at conferences and universities.  Ms. Hermida is a member of the New York City Bar Association and the New York State Bar Association.

Ms. Hermida holds a degree in finance from the Stern School of Business of New York University and a J.D. from Fordham University School of Law.


Mark Ehrlich is Vice President, Global Ethics and Compliance at Hilton. Mark is responsible for all aspects of Hilton’s global corporate compliance program, with a particular focus on anti-corruption laws and international trade restrictions, as well as Hilton’s data privacy and security programs.  He oversees third party due diligence, internal investigations, ethics and compliance training, as well as information security risk assessments and incident response.

Prior to joining Hilton, Mark served in compliance roles with The AES Corporation, a global power company, and with MCI/WorldCom where he participated in developing an ethics and compliance program following the discovery of WorldCom’s financial improprieties.  In addition to his work in the ethics and compliance field, Mark has extensive litigation and regulatory experience, serving as in-house counsel with the MCI regulatory litigation group, attorney advisor at the Federal Communications Commission (FCC), and trial attorney with the U.S. Department of Justice in the Civil Division’s Commercial Litigation Branch.


Nora Kurzova  has been with Tyco since 2007. She has served in multiple roles including Commercial Lawyer for Eastern Europe, Compliance Counsel EMEA and most recently is Chief Privacy Officer for Tyco globally.

Nora started her academic career with undergraduate studies of Law and Forensic Science at the Police Academy in Prague, then earned her masters in general law at Charles University in the Czech Republic followed by post graduate studies and a doctoral degree in Criminal law and forensic science.  She then completed LLM degree in International Public and Criminal law from  the University of Greenwich, UK. Currently Nora is enrolled in a non-degree program and is studying Cryptography and Computer Science at Princeton University.

Nora speaks English, Czech, Russian, French and Slovak and her area of expertise next to data privacy and data protection is criminology with a focus on regulation of corruption and fair competition.

Before joining Tyco Nora has worked for the Czech Criminal Police  where she assisted investigations of organized crime and also taught Introduction to Law and Forensic Science at a Mensa gymnasium in Prague.

Nora has contributed to various periodicals in the Czech Republic on regulation of corruption and has developed a standard on Collecting and Handling DNA evidence for the Department of Forensics in the Czech Republic.


Paul E. McGreal is Dean and Professor of Law at the Creighton University School of Law.  He became dean on July 1, 2015. At Creighton, he is working with the Business Ethics Alliance on programs and projects to support compliance and ethics professionals, and he participates in the Alliance’s VP Ethics Exchange.

Dean McGreal also teaches in the Texas A&M University Executive MBA Program, which he has done since the Program’s inception in 1999.  His courses there have included modules on corporate vicarious liability, domestic and foreign anti-corruption laws (including the Foreign Corrupt Practices Act), corporate compliance and ethics programs, business ethics, and corporate governance. 

Dean McGreal was previously dean of the University of Dayton School of Law from 2011 to 2014.  Before that, he was associate dean and professor of law at Southern Illinois University School of Law, where the graduating class voted him the Senior Class Award in 2008, 2009, and 2010.

Prior to joining SIU, Dean McGreal established the Corporate Compliance Center at the South Texas College of Law, where he taught for 10 years.  While at South Texas, he created and taught the first course on corporate compliance and ethics programs offered at a United States law school.

Dean McGreal has also taught as a visiting professor at George Mason University School of Law and Southern Methodist University’s Dedman School of Law.

Dean McGreal’s areas of expertise include corporate compliance, business ethics, constitutional law, religion and the law, and First Amendment rights.  He is a frequent speaker and commentator on corporate compliance and ethics programs, and he authors an annual survey of legal developments on the subject for The Business Lawyer, published by the Business Law Section of the American Bar Association.   He has also published over 40 articles and essays in law journals at schools including University of Notre Dame, Northwestern University, and the University of Pennsylvania.

Before teaching, he worked in the Dallas office of Baker Botts LLP. After graduating from law school, he served as law clerk for Justice Warren Matthews of the Alaska Supreme Court.

Dean McGreal earned an LL.M. from Yale Law School, a J.D. from the Dedman School of Law at Southern Methodist University, and a B.A. in economics from Williams College.


Seth M. Cohen
Director, Performance Governance, Risk and Compliance
PricewaterhouseCoopers (PwC) LLP

Seth Cohen is a Director in the Performance Governance, Risk and Compliance (PGRC) group of the Assurance practice at PwC LLP. He provides compliance services for Fortune 500 and other companies, including compliance program reviews, compliance risk assessments and support in compliance policy and training program development and implementation. Seth has been with PwC since April 2014. Prior to that role, Seth was the Director of Global Ethics & Compliance at Avaya Inc., where his responsibilities included the day-to-day management of the company’s global ethics and compliance program, focusing on ethics and compliance policies, communications and training, anti-bribery/anti-corruption, conflicts of interest, data privacy and social media issues. From 2006 to 2012, Seth was Head of Policy and Processes for Zurich Financial Services’ Office of Compliance North America, where he assisted in the development of the regional compliance function and supported Zurich's response to its regulatory settlement agreements. Seth also led the company’s global practice group on competition and antitrust, and provided compliance support to Zurich's alternative asset management group. Prior to arriving at Zurich, Seth was a manager in the Forensic practice at KPMG from 2001 to 2006, where he conducted investigations and compliance and governance assessments for both public and private companies. He began his career as an Assistant District Attorney in Bronx County, NY, and followed that experience as an investigative attorney for the New York City Department of Investigation. Seth is a Certified Fraud Examiner (CFE) and a member of the Association of Certified Fraud Examiners and the American Bar Association. Seth is the former chairman of the Ethics and Compliance Officers Association’s (ECOA) Financial Services Industry Group and has also published several articles in external publications and spoken on compliance-related topics at a number of conferences and seminars. Seth is a graduate of the Massachusetts Institute of Technology and the George Washington University Law School.


STEPHEN C. KING

Stephen C. King serves as Legal Senior Director for Critical Risk Areas and Chief Compliance Investigator for PepsiCo, Inc. in the Global Compliance & Ethics Department at PepsiCo Headquarters in Purchase, NY. He has more than 20 years of experience in investigations and compliance.

Stephen manages the Compliance & Ethics Program across the Corporate, Global Groups and Horizontal functions. He is responsible for identifying, analyzing and responding to critical risk areas that might adversely affect PepsiCo’s business objectives. He conducts internal investigations associated with allegations of potentially significant violations of PepsiCo’s Code of Conduct or the law, including the FCPA and other anti-bribery laws. Stephen also leads the company’s in-country anti-corruption compliance assessments and oversees the continuing development and implementation of the global due diligence program and tool-kit.

Prior to joining PepsiCo, Stephen served as a federal prosecutor in the Eastern District of New York for ten years, where he investigated and prosecuted hundreds of cases, including matters involving public corruption, organized crime, terrorism, narcotics, solicitation and receipt of kickbacks and embezzlement.

Following the attacks of September 11, 2001, Stephen served as the Director of Investigations and Law Enforcement in the White House Office of Homeland Security (now the White House Homeland Security Council), where he helped develop policies to assist federal, state and local law enforcement officials coordinate interagency terrorism investigations and responses to threats and incidents.

In 2005, Stephen was nominated by President George W. Bush to serve as a member of the Foreign Claims Settlement Commission of the United States, a quasi-judicial, independent agency within the Department of Justice, which adjudicates claims of U.S. nationals against foreign governments. In 2006, he was unanimously confirmed by the U.S. Senate. In 2008, Stephen joined Raytheon Company as a Senior Counsel, where he was responsible for internal investigations and compliance matters.

Stephen holds a B.A. from Wesleyan University and a J.D. from the Columbia University School of Law. Stephen was an attorney on the Corporate Internal Investigations Team of Sidley & Austin and the Litigation and Regulatory team of Hunton & Williams. He taught courses on Emergency Management & Response Law and Border & Homeland Security Law as an Adjunct Assistant Professor of Law at Brooklyn Law School. He is a former president of the Federal Bar Association’s Eastern District of New York Chapter and a Certified Compliance & Ethics Professional in the Society for Corporate Compliance & Ethics.

Stephen is a member of the New York bar and admitted to practice before the U.S. Supreme Court, U.S. Court of Appeals for the Second Circuit, U.S. Court of International Trade and U.S. District Courts for the Eastern, Northern and Southern Districts of New York.

He resides in Lewisboro, NY with his wife and four children.


Work Experience

Alabama Power Compliance Director – Provides oversight for the design, implementation, enforcement, and modifications of compliance management programs for Alabama Power Company.  Alabama Power is an electric utility in Alabama serving 1.4 million customers with annual revenue of $5.5 billion.  Also responsible for Company’s EEO Program and contract manager for external affairs professional services agreements. (2004 to Present)

Southern Company Generation Compliance Director – Overall Compliance Program coordination / management for Southern Company Generation.  Southern Company Generation is responsible for the management of the Southern Company’s Generation Fleet – over 80 generating plants producing over 42,000 megawatts of power.  (2002-2004)

Southern Company Internal Auditing - Compliance Director - As Compliance Audit Director, responsible for assessing compliance risks for Southern Company and for managing compliance audits of all Southern Company subsidiaries (environmental, safety and health, employment, etc.).  During audit career, performed and managed all types of audits including operational, financial, compliance, management requests, and fraud investigations.  Environmental auditing experience began in 1981.  (1975 – 2002)

Other Activities:

Board of Environmental Auditor Certification (BEAC) Board of Directors. (2002-2008)

American Chemistry Council Responsible Care Technical Oversight Board – Member of Board responsible for oversight of Responsible Care, 3rd party certification program within the U.S. Chemical Industry.  (2003-2008)

Edison Electric Institute (EEI) Peer Review Program Director - Director of Peer Review Program that provides for the evaluation of a member utility’s environmental audit program. (1997-2000)

EEI Environmental Auditing Taskforce Vice-Chairman (1994-1996)

United States Energy Association - Part of delegation that conducted environmental management and auditing seminar for four Eastern Europe countries in Slovakia (1995) and in Atlanta (1996)

Education / Certifications

B.S. Accounting, University of Alabama

Certified Internal Auditor (CIA), Certified Professional Environmental Auditor (CEPA) and Certified Fraud Examiner (CFE)

 


Kathy has been with AT&T or it predecessor companies for over 35 years.  Since 1990 she has been involved in some type of compliance function, from Regulatory Compliance to Corporate Compliance & Ethics.  Among her accomplishments, she created a new compliance program for Cingular Wireless, successfully completed a major code rewrite at AT&T and created an Integrated Governance Council to analyze ethical violations across the organization.  On her current job, she is responsible for AT&T’s Compliance & Ethics Program. 

Kathy is married, with 2 grown sons and a daughter who just started college last fall. 


Ed Petry, Ph.D., joined NAVEX Global Advisory Services in 2004 after almost ten years as executive director of the Ethics and Compliance Officer Association (now part of ECI).  Ed served on the Advisory Panel to the U.S. Sentencing Commission which was responsible for the 2004 revisions. Earlier in his career he was a tenured professor of ethics and a prolific author and researcher and served on various boards and oversight committees for ethics organizations including the Ethics Oversight Committee for the U.S. Olympics. As Vice President with Advisory Services, Ed applies his more than 30 years of experience to help companies assess their ethics and compliance programs. He has also helped more than 250 companies develop and improve their codes of conduct.


Gary F. Giampetruzzi is a partner in the Litigation Department of Paul Hastings, based in the firm’s New York office. Prior to joining Paul Hastings, Mr. Giampetruzzi most recently served as Vice President, Assistant General Counsel and Head of Government Investigations at Pfizer Inc, with responsibility for government investigations across the company’s multiple business units and operations globally, and associated government litigation with U.S. and international prosecutor offices. He was previously a Deputy Compliance Officer responsible for international compliance investigations and programs with responsibility for the implementation and maintenance of compliance programs and systems across the company's international operations, with an enhanced focus on emerging markets. He routinely advises clients on day-to-day compliance matters, and represents corporations in high-profile federal and state investigations, including those involving federal and state False Claims Act (qui tam suits), State Attorney General consumer protection statutes, the Foreign Corrupt Practices Act (“FCPA”), and oversees other complex civil and criminal litigation matters.

Mr. Giampetruzzi is highly regarded by counsel, healthcare industry insiders, and regulators for his strategic thinking and sound judgment in handling some of the most significant regulatory investigations in the pharmaceutical industry in recent years. He understands how to engage appropriately with the regulators, and how to litigate effectively when that should become necessary. He brings unique experience and perspective to each client representation, having himself been the client for more than a decade at one of the largest multi-national corporations in the world. During that time, he partnered closely with his business colleagues and various platform functions, and helped navigate a complex organization through some of the most significant compliance and enforcement issues faced in the pharmaceutical industry. As a senior leader, Mr. Giampetruzzi routinely operated at the executive leadership team and board levels, and understands from his firsthand experience that the particular needs of each client and circumstance are different, and that the approach and solutions must be too. Mr. Giampetruzzi genuinely appreciates the pressures and realities facing clients and in-house counsel, and works with them to understand and achieve their specific goals.

Mr. Giampetruzzi has extensive experience with all facets of the anti-corruption and FCPA landscape. He has been a leader in this growing area of practice for more than a decade, having led the development of cutting edge compliance programs and measures, conducted and overseen hundreds of internal investigations, and been on the ground in more than 40 markets worldwide (including Asia, Africa, Europe, the Middle East, and Latin America). He was instrumental in the development of proactive market review approaches that have been incorporated into recent government resolutions, and acquisition due diligence techniques that were cited in the Justice Department’s FCPA Guidance document. He has the proven and longstanding ability to provide end-to-end support, from front-end compliance counseling and program build-outs and enhancements, to the efficient conduct of global internal investigations, to the defense of companies before U.S. and international authorities, while keeping an appropriate eye towards the increasing risk of follow-on civil litigation.

Recent Representations

  • Mr. Giampetruzzi has also been a practice leader in the U.S. healthcare enforcement area, having been in the middle of some of the most significant cases to date.
  • Oversaw the negotiations, finalization of terms and preparations for the announcement of the landmark $2.3 billion civil and criminal, off-label promotion and kickback investigations with the Boston, Philadelphia, and other U.S. Attorney’s Offices, Main Justice, HHS OIG, and State Medicaid Fraud Control Units (largest criminal case in history at the time) and the $491 million civil and criminal, off-label promotion investigation with the Western District of Oklahoma U.S. Attorney’s Office, Main Justice, HHS OIG, and State Medicaid Fraud Control Units.
  • Oversaw the negotiation and resolution of the grand jury investigation into the promotion of the $10 billion in sales, drug Protonix by the Boston U.S. Attorney’s Office, achieving a novel, civil-only resolution entailing $55 million in disgorgement under the Food, Drug, & Cosmetics Act.
  • Oversaw internal investigations and associated voluntary disclosures under the FCPA for a pharmaceutical company involving numerous markets around the world to the U.S. Department of Justice and SEC, and certain foreign authorities, beginning in 2004, and concluding in 2012. Secured a full declination for the parent company, a deferred prosecution agreement for the relevant corporate subsidiary, no imposition of an independent monitor, and explicit government recognition of the company’s efforts.
  • Oversaw the acquisition due diligence, resultant internal investigations in numerous markets and associated voluntary disclosures to the U.S. Department of Justice and SEC, which resulted in a full declination for the parent company and subsidiaries, and a purely civil resolution.
  • Defended a pharmaceutical company against government inquiries and investigations by the Chinese Administration of Industry and Commerce (“AIC”) in Beijing, Shanghai and other cities and provinces across China.
  • Oversaw the defense and resolution of numerous whistleblower qui tam suits involving claims under the False Claims Act and related state statutes.
  • Oversaw the successful resolution of several individual State Attorney General and multi-state AG coalition matters, including the $33 million consumer protection settlement with a coalition of 44 states around the promotion of Geodon, and the $45 million consumer protection settlement with coalition of 34 states around the promotion of Zyvox and Lyrica.
Accolades and Recognitions

Mr. Giampetruzzi brings creative lawyering to bear on each of his client’s challenges, with some of the compliance approaches he developed having become a best practice (e.g., proactive FCPA market reviews, now routinely in government resolutions), and even being cited in the U.S. government’s FCPA guidance document (e.g., FCPA acquisition due diligence).

Speaking Engagements and Publications
  • Mr. Giampetruzzi is a frequent speaker at industry conferences on a variety of white collar defense topics, including global compliance programs, government investigations, state and federal U.S. healthcare enforcement, and the Foreign Corrupt Practices Act.
  • Program Faculty, Seton Hall Law School, U.S. Healthcare Compliance Program
Education

Saint John’s University School of Law, J.D., 1993


Janice Innis-Thompson is a Senior Advisor for Compliance Strategies, a leading consulting firm specializing exclusively in compliance, ethics, risk and governance practices.  Until June of 2016, Janice was Senior Managing Director, Chief Compliance and Ethics Officer, a role she served in for nine and a half years. Ms. Innis-Thompson oversaw and managed TIAA’s enterprise wide compliance and ethics program. She led a team of more than 150 compliance professionals who transformed TIAA’s Compliance Program from an Insurance-centric program to a multi-regulated program driven by the Federal Reserve Bank.  She also created TIAA’s Ethics program, which won Ethisphere’s Awards in 2014 and 2015, ranking TIAA as one of the most Ethical Companies in the World.

Ms. Innis-Thompson joined TIAA in October 2006 from Tyco International, where she was Chief Compliance Counsel. Prior to that, she was the Chief Compliance Counsel at the International Paper Company. Ms. Innis-Thompson began her career with the United States Department of Justice, where she was an Assistant U.S. Attorney in three jurisdictions. During that time she also served a year as Counsel to the Director of EOUSA (Executive Office for United States Attorneys), and worked with Attorney General Janet Reno during the 1996 election. Ms. Innis-Thompson holds a B.A. with honors and a J.D. from the University of Florida. She is a board member of Edward Jones’ Bridge Builder Trust Fund, where she chairs the nominating and governance committee. She also serves on the boards of the NYPD Audit Advisory Committee and the Wardlaw-Hartridge School. She is an active member of several industry groups including the Compliance & Ethics Leadership Counsel and Corporate Executive Board.


Mr. Kaplan is a partner in Kaplan & Walker LLP, a law firm in Princeton, New Jersey and Santa Monica, California.   For more than twenty years he has specialized in assisting companies in developing, implementing and reviewing corporate compliance/ethics programs. This work has included conducting risk analyses; writing/editing codes of conduct and other policy documents; counseling companies in matters regarding training; developing compliance audit protocols and reporting systems; establishing compliance/ethics offices; and assisting boards of directors in meeting their fiduciary duties under the Caremark case.  He has also conducted numerous program assessments. Mr. Kaplan’s compliance/ethics program practice has included work for clients in the health care, medical devices, pharmaceuticals,  government contracting,  insurance, manufacturing, energy, retail, paper, publishing, professional services, telecommunications, technology, securities, private investments, food and chemical fields, as well as non-profit organizations.

Mr. Kaplan is currently an anti-corruption compliance consultant for two companies that were suspended by the World Bank, has served as a compliance monitor in a criminal tax case for the New York County District Attorney, has reviewed and reported to the Department of Justice and SEC on a company’s compliance/ethics program in connection with the settlement of an FCPA investigation and has reviewed and reported to a state attorney general on another company’s compliance/ethics program in connection with a settlement of another matter.  He also conducts internal investigations on behalf of boards and companies into allegations of wrongdoing brought by whistleblowers and others and practices in the areas of regulatory and white-collar criminal defense.  He received his B.A. (magna cum laude, Phi Beta Kappa) from Carleton College in 1976 and his J.D. (cum laude) from Harvard University in 1980.  He is a former partner of Chadbourne & Parke, where he served in the Special Litigation Group, and also a former partner of Arkin Kaplan & Cohen LLP and of Stier Anderson, LLC. 

For many years Mr. Kaplan was Counsel to the Ethics Officer Association (now the ECOA), a professional association of more than 1000 compliance/ethics officers. He also founded and served as the Program Director of the ECOA’s ‘law school” and “global law school” for compliance/ethics officer. He was Program Director for the Conference Board’s annual Business Ethics conference and its Council on Corporate Compliance and co-authored two research reports for the Conference Board:   Ethics Programs – The Role of the Board: A Global Study and Ethics and Compliance Enforcement Decisions – the Information Gap (both with Ronald Berenbeim).  In 2009 he was a recipient of a Compliance and Ethics Award from the Society for Corporate Compliance and Ethics, which that organization bestows annually on “Compliance and Ethics Champions.” 

Mr. Kaplan is, together with Joe Murphy, co-editor of Compliance Programs and the Corporate Sentencing Guidelines: Preventing Criminal and Civil Liability (West 1993), a leading legal treatise on designing and implementing compliance/ethics programs.  He is co-author of The Prevention and Prosecution of Computer and High Technology Crime (Matthew Bender 1989) and author of an e-book on risk assessment issued by Corporate Compliance Insights.  He was for many years co-publisher/executive editor of ethikos, a bimonthly magazine covering compliance/ethics best practices  He is author and co-author of numerous articles about business crime and compliance/ethics programs in periodicals such as The California Management Review, The Journal of Securities and Commodities Regulation, The Prevention of Corporate Liability: Current Report, The Preventive Law Reporter, Directorship, Director’s Monthly, American Banker, Business Crime Commentary, the New York Law Journal and the National Law Journal, and also various book chapters on these topics.

Mr. Kaplan is a co-chair of the Practicing Law Institute’s annual Advanced Compliance and Ethics Workshop and for many years chaired the Continuing Legal Education program in corporate compliance sponsored by the Association of the Bar of the City of New York. He is editor of the Conflict of Interest Blog and a regular columnist for Compliance and Ethics Professional magazine. Mr. Kaplan was for many years Adjunct Professor of Business Ethics at the Stern School of Business, New York University.  He is now a researcher on the Ethical Systems project which is run by a professor at that school. He is a member of the New York and New Jersey bars.