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Compliance and Ethics Program Assessments


Speaker(s): Jeffrey M. Kaplan, Rebecca Walker
Recorded on: Apr. 6, 2016
PLI Program #: 176429

Jeffrey M. Kaplan is a partner in the Princeton, New Jersey office of Kaplan & Walker LLP.   For twenty-five 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, automotive, government contracting, insurance, manufacturing, energy, retail, paper, publishing, professional services, education, consulting, telecommunications, technology, securities, private investments, food and chemical fields, as well as non-profit organizations. 

Mr. Kaplan has, on three occasions, been an independent consultant for companies suspended by the World Bank, reporting to the Bank on their respective compliance programs, and performed a similar review for the United Nations; 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-related investigation; and has reviewed and reported to a state attorney general on another company’s compliance/ethics program in connection with a settlement of a fraud-related matter.  He also conducts internal investigations on behalf of boards and companies into allegations of wrongdoing brought by whistleblowers and others.  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 ECI), a professional association of more than 1000 compliance/ethics officers.  He 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 author of an e-book on risk assessment issued by Corporate Compliance Insights.   He is editor of the Conflict of Interest Blog.  He was for many years Adjunct Professor of Business Ethics at the Stern School of Business, New York University.  He is now a contributor to the Ethical Systems research project which is run by a professor at that school, and has recently co-authored an e-book for Ethical Systems on behavioral ethics and compliance. He is a member of the New York and New Jersey bars.


Rebecca Walker is a partner in the Santa Monica, California office of Kaplan & Walker LLP, a law firm that assists organizations in developing, implementing and improving their corporate compliance and ethics programs. For nearly twenty years, Ms. Walker has specialized in advising clients on the development and implementation of compliance and ethics programs that are tailored to each client's legal risks and business needs and that conform to applicable government requirements and pronouncements. Ms. Walker has counseled numerous companies in diverse industries on the various components of their compliance and ethics programs, including:

  • Assisting organizations in effectively structuring their programs;
  • Drafting and revising codes of conduct and other policies and procedures, including conflicts of interest and anti-corruption policies and procedures;
  • Developing and delivering compliance training and assisting in the development of compliance training and communications plans;
  • Developing reporting systems, investigations procedures and investigations training; and
  • Developing risk assessment processes and conducting compliance risk assessments.

Ms. Walker has also conducted numerous assessments of compliance and ethics programs, including assessments of entire programs as well as “deep dive” assessments of program elements, such as investigations procedures and program structure, and subject matter areas, such as conflicts of interest and anti-corruption programs.  She has also served as a monitor for the Department of the Air Force and as an independent consultant reviewing programs for the U.S. Securities and Exchange Commission.

Ms. Walker’s clients have included companies from the oil and gas, government contracting, engineering/construction, energy, financial services, pharmaceutical, health care, banking, automotive, publishing, advertising, consulting, telecommunications, retail, consumer products, apparel, railroad and shipping industries, among others, including many companies in the Fortune 500.

Ms. Walker chairs the Practising Law Institute's annual Compliance and Ethics Institute in New York and their annual Advanced Compliance and Ethics Workshop in San Francisco.  Ms. Walker serves on the Advisory Board of the Compliance and Ethics Professional Magazine, published by the Society of Corporate Compliance and Ethics (SCCE) and on the Editorial Board of the Complete Compliance and Ethics Manual. For seven years, Ms. Walker served on the Advisory Board of the SCCE, the largest association of compliance professionals in the world.  For many years, she also served on the Advisory Board of the Corporate Compliance Center at the South Texas College of Law. Ms. Walker is the author of Conflicts of Interest in Business and the Professions: Law and Compliance, published by Thomson West in 2005.  She is the co-author of a number of compliance surveys, published by The Conference Board, the SCCE and others. Ms. Walker has also published numerous articles regarding compliance and ethics.  Ms. Walker is a frequent speaker on compliance and ethics issues, including for the Practising Law Institute, the SCCE, The Conference Board, and other legal and business groups.

Ms. Walker received her B.A. (magna cum laude, Phi Beta Kappa) from Georgetown University and her J.D. (cum laude) from Harvard Law School.