Search results

To explain and analyze two Enforcement Advisories that set forth the factors the US Commodity Futures Trading Commission Division of Enforcement may consider in assessing cooperation by companies and individuals in the context of CFTC enforcement proceedings.

Explains the background, including the 2007 Enforcement Advisory for Companies. Explains the 2017 Enforcement Advisory for Companies and the parallel Enforcement Advisory for Individuals, including policy-based considerations and factors such as the materiality, timeliness, nature, and quality of a company’s cooperation; the value of a company’s cooperation to the Commission’s broader law enforcement interests; and the company’s culpability, culture and other relevant factors. Provides examples of uncooperative conduct. Discusses a broader trend among enforcement authorities in the US and abroad of setting higher cooperation standards.

The new Advisories make clear that merely complying with requests for information from the CFTC staff will not be sufficient; a company or individual seeking cooperation credit as part of a resolution with the CFTC must go above and beyond its legal obligations in order to qualify for such credit.

Practical guidance from experienced white collar defense, regulatory enforcement, civil litigation and arbitration lawyers.

To explain a recent enforcement action by the US Securities and Exchange Commission (SEC) highlighting risk factors for Foreign Corrupt Practices Act (FCPA) violations.

Summarizes the basis of the SEC’s enforcement action against Sanofi for violating the FCPA’s books and records and internal controls provisions, reviews the terms of the SEC’s resolution with Sanofi, explains Sanofi’s remedial efforts and cooperation with the SEC’s investigation, and discusses factors contributing to corruption risks in the healthcare industry.

The SEC’s enforcement action against Sanofi, and other recent enforcement actions, underscore the importance of comprehensive anti-corruption compliance programs and strong internal controls across large multinationals and their subsidiaries.

Companies operating in high-risk industries and markets should regularly assess and address corruption risks.

Practical guidance from experienced enforcement lawyers.

This paper explores the impact of a suite of alcohol culture change interventions implemented by Deakin University in Melbourne, Australia. The interventions were designed to change the alcohol culture at a bi-annual nation-wide university multi-sport competition known as Uni Nationals. This study aims to understand the critical success factors of the alcohol culture change initiatives that were developed by the university and implemented as part of a broader set of institutional practices.

A qualitative research design utilised in-depth, semi-structured interviews with nine Uni Nationals student team leaders. In total, two group interviews and four individual interviews were conducted with student team leaders who participated in the Uni Nationals. The interview transcripts were coded and themed. The themes were further refined and interpreted into a narrative. A total of two transcripts were independently coded by the first two authors. Discordant coding was flagged and discussed until a consensus was achieved. The remaining interviews were coded by the first author and discussed with the second author to ensure consistency. A socio-ecological framework was used to understand perceived changes to alcohol culture.

Student leaders were aware of and felt supported by the university-wide approach to changing the culture of Uni Nationals. Overall, the qualitative study indicated that students were positive about the alcohol culture change interventions. The leadership training that engaged team leaders in interactive activities had the greatest impact. Student leaders found the targeted messages, mocktail events and Chef de Mission (CdM) less effective cultural change strategies. However, they helped to establish expectations of students in this setting where a heightened focus on sport was associated with higher alcohol consumption.

While there has been growing academic interest in exploring “drinking cultures”, there has been relatively little focus on alcohol culture of university students at sporting events. The paper contributes to addressing this gap by shedding light on the impact of a group of interventions on the drinking culture of the Uni Nationals subculture.

This study aimed at developing and testing a model to evaluate employee performance in Isfahan municipality.

A mixed-method design is applied in this study. To extract the model, a semi-structured interview based on the thematic analysis approach was employed. The qualitative data were obtained using a researcher-made questionnaire from a sample of 12 municipal experts selected based on purposive sampling. In the quantitative phase, the sample consisted of 76 managers and interim managers. The validity of the questionnaire was determined by the content validity index, while the structural validity was tested based on structural equation modeling using SmartPLS software. The reliability of the questionnaire was confirmed using Cronbach's alpha and composite reliability indices.

The factors obtained in the qualitative model included performance evaluation criteria, the desired time interval for performance evaluation, results announcement, performance evaluation approach, performance evaluation method and evaluator-related variables. There should have been an agreement between evaluators and those who were evaluated in all components of the model. In the quantitative section, performance evaluation criteria, evaluators, the evaluation method and time interval were confirmed with coefficients of 0.871, 0.815, 0.646 and 0.615, respectively.

The novelty of this study is that it uses a mixed-method research approach to extract a performance evaluation model that is specific to the Isfahan municipality.

The novelty of this study is that it uses a mixed-method research approach to extract a performance evaluation model that is specific to the Isfahan municipality.

Aarhus Kommunes Biblioteker (Teknisk Bibliotek), Ingerslevs Plads 7, Aarhus, Denmark. Representative: V. NEDERGAARD PEDERSEN (Librarian).