Duty, Honor, Country

The Sylvanus Thayer Award is an honor given annually at the United States Military Academy to someone whose accomplishments exemplify the motto of West Point. Thayer was a graduate of Dartmouth College, and later from West Point. Following a distinguished military career, Colonel Thayer was appointed by President James Monroe as Superintendent at the Academy in 1817. Under his leadership West Point became the nation’s first college of engineering. During Thayer’s tenure the Academy established numerous academic advances, policies and traditions, still in effect today, for which he is credited as the “Father of West Point.”

In 1958 the West Point Association of Graduates established the Sylvanus Thayer Award to recognize a citizen of the United Sates, whose character, accomplishments, and stature exemplify the qualities for which the West Point motto strives: Duty, Honor, Country. It is an honor that must be received at the Academy. In 1962 the West Point Association of Graduates chose to honor (Ret.) General of the Army, Douglas MacArthur. It became his farewell address.

On May 12th that year, MacArthur left the Waldorf Astoria Hotel where he lived, and proceeded to West Point, where he spoke to the Corps in the mess hall. He referred to the Academy’s motto – Duty, Honor, Country – as a “moral code.” His words are among the most eloquent ever spoken and, in these troubled and divisive times, a welcome source of inspiration and comfort today. Here are some excerpts:

Duty, Honor, Country: These three words reverently dictate what you ought to be, what you can be, what you will be. They are your rallying points: to build courage when courage seems to fail; to regain faith when there seems to be little cause for faith; to create hope when hope becomes forlorn.

The unbelievers will say that they are but words, but a slogan, but a flamboyant phrase. Every pedant, every demagogue, every cynic, every hypocrite, every troublemaker, and, I am sorry to say, some others of an entirely different character, will try to downgrade them even to the extent of mockery and ridicule.

But these are some of the things they do. They build basic character.…They make you strong enough to know when you are weak, and brave enough to face yourself when you are afraid.

They teach you to be proud and unbending in honest failure, but humble and gentle in success; not to substitute words for actions; not to seek the path of comfort, but to face the stress and spur of difficulty and challenge; to learn to stand up in the storm, but to have compassion for those who fall; to master yourself before you seek to master others; to have a heart that is clean, a goal that is high; to learn to laugh, yet never forget how to weep; to reach into the future, yet never neglect the past; to be serious, yet never take yourself too seriously; to be modest so that you will remember the simplicity of true greatness; the open mind of true wisdom, the meekness of true strength.”

When MacArthur spoke of the soldiers he led, he said:

“I do not know the dignity of their birth, but I know the glory of their death. They died unquestioning, uncomplaining, with faith in their hearts, and on their lips the hope that we would go on to victory. Always for them: Duty, Honor, Country. Always their blood, and sweat, and tears, as they saw the way and the light…. The code which those words perpetuate embraces the highest moral laws and will stand the test of any ethics and philosophies ever promulgated for the uplift of mankind. Its requirements are the things that are right, and the restraints are the things that are wrong. The soldier, above all other men, is required to practice the greatest act of religious training – sacrifice.”

“You now face a new world, a world of change…. All through this welter of change and development your mission remains fixed, determined, inviolable.”

As he came to the close of his remarks, MacArthur said:

“The shadows are lengthening for me. The twilight is here. My days of old have vanished – tone and tints. They have gone glimmering through the dreams of things that were.  Their memory is one of wondrous beauty, watered by tears and coaxed and caressed by the smiles of yesterday. I listen to them, but with thirsty ear, for the witching melody of faint bugles blowing reveille, of far drums beating the long roll.

In my dreams I hear again the crash of the guns, the rattle of musketry, the strange mournful mutter of the battlefield. But in the evening of my memory I come back to West Point. Always their echoes and re-echoes: Duty, Honor, Country.

Today marks my final roll call with you. But I want you to know that when I cross the river, my last conscious thoughts will be of the Corps, and the Corps, and the Corps. I bid you farewell.”

These are troubling times. A still surging life-threatening virus has brought the entire planet to its knees. Health systems and front line warriors are completely overwhelmed and at risk. In our attempt to respond to COVID-19 by sheltering-in-place, we face a global economic collapse not seen since the Great Depression, which has further exposed racial and economic divisions, all made worse by the spread of disinformation and hatred. Particularly hard hit by the pandemic have been black and brown communities, the poor, and the elderly. It is our most vulnerable that have suffered the most. This has resulted in a profound loss of trust in our leaders and institutions. The void must be filled by those of us who, individually and collectively, will carry the torch forward in response to these crises, propelled by our commitment to Duty, Honor, Country.

Keith Darcy is President of Darcy Partners Inc., a boutique consulting firm that works with boards and top executives on a wide variety of complex governance, ethics, compliance, and reputation risk challenges. (Website: Darcy.Partners)


I recently came across this previously unpublished blog, written some time ago. Like so many other essays, the message often changes with the times.


Keith Darcy

Life is the great gift that has been given to each of us. What we do with our life is our gift in return. Each of us finds different ways to express this. We are, each of us, one-of-a-kind.  No one sees the world just as we do.  Our purpose in life is to discover, and express fully, the uniqueness that is distinctly ours.

Some years back my great friend, Dennis, went on a three-day religious a retreat in southern New Jersey. It was a weekend structured for spiritual contemplation and reflection. Beginning Friday morning, the participants met periodically as a group — in silence — to hear a spiritual message, then split up to reflect upon the message individually, while walking in the sacred surroundings of the gardens, through the woods, or along the mountain ridge. The only exception to the rule of silence was time the scheduled for Sunday at lunch.

The participants at the retreat all came from different churches in New Jersey. Among this large gathering were a few people Dennis recognized from his parish in Summit, but he did not know them well. Curiously, as he looked out among the many strange faces, he wondered who were these people, where they came from and why they were there.

At lunch on Sunday, Dennis was making his way through the cafeteria line when the man standing next to him said “Hello.”  Dennis did not recognize this man, but politely returned the greeting. This stranger then said to Dennis, “You may not recognize my face any more than I recognize yours, but I do know you by your shoes.” Dennis’ face looked appropriately puzzled. The stranger then said, “I’m your shoemaker, and I’d recognize those shoes anywhere. Whenever you brought them to me for repair, it was important that I gave them the same care that you did.”

When Moses went to the top of the mountain to receive the commandments, a Voice from the burning bush said to him, “Moses, take off your shoes.” It was understood by that order that the ground he walked on was holy. Indeed, the ground we walk on is holy.  So are the shoes we wear.  So, too, are the gifts of the shoemaker. 

Nietzche once wrote, “At bottom every man knows well enough that he is a unique human being, only once on this earth; and by no extraordinary chance will such a marvelously picturesque piece of diversity in unity as he, ever be put together a second time.”

Each of us is born with gifts differing. This is our uniqueness, to express fully. Whether we are butcher, baker or candlestick maker there is always the opportunity to creatively contribute to life by polishing that which is already beautiful. Life is the medium, and we are the canvass. Thus is the art of living.

After reading this, I reflected on several things relative to today’s crisis:

  • As we are required to hide behind masks for health reasons, unrecognizable to some, there are so many other ways we are recognized. The shoemaker recognized my friend Dennis by his shoes, and the care he took, which prompted him to make sure he gave similar care and attention. It calls out the importance of reciprocity.
  • Each of us has something unique to contribute. Our first responders and frontline medical people are making extraordinary sacrifices to keep us safe, at great risks to themselves. So, too, the transit workers, grocery clerks, postal workers, and package deliverers, among many others. Each of us has out part to play, and it takes all of us working together when times are tough.
  • As scientists study the cause-and-effect relationship between climate change and pandemics, let us never forget that the ground we occupy is holy. It is the source of our sustenance.
  • Lastly, let us remember the power of prayer. Many people pray for guidance, solace, protection, or thanks giving. In the midst of all that troubles us, let us all consider a moment of silence, and in that silence be grateful for our many blessings.

Mary Oliver, the Pulitzer Prize winning poet, wrote this poem, Praying:

It doesn’t have to be
the blue iris, it could be
weeds in a vacant lot, or a few
small stones; just
pay attention, then patch

a few words together and don’t try
to make them elaborate, this isn’t
a contest but the doorway

into thanks, and a silence in which
another voice may speak.

Indeed, life is the medium, and we are the canvas. Let us strive to polish all of which is already beautiful.

Keith Darcy is President of Darcy Partners Inc., a boutique consulting firm that works with boards and top executives on a wide variety of complex governance, ethics, compliance, and reputation risk challenges. Website: Darcy.Partners

A Commencement Address

The world is a mess.

A still-surging life-threatening virus has brought the entire planet to its knees. Health systems and front line warriors are completely overwhelmed and at risk. In our attempt to respond to COVID-19 by sheltering-in-place we face a global economic collapse not seen since the Great Depression. Particularly hard hit by the pandemic have been people of color, the poor, and the elderly. It is the least of us that have suffered the greatest losses. 

Given the absence of a federal response individuals, organizations, and states have been left to fend for themselves. They are competing for scarce resources, most especially to provide first responders and medical workers with the protective equipment necessary to keep them safe. The absence of ventilators vastly increased risks to patients in the hospitals, and to those trying to protect them. And the lack of a coordinated national strategy has endangered everyone. It is an extraordinary and unprecedented failure of leadership.

For the class of 2020, these are overwhelming obstacles to overcome. The challenge for these graduates is to decide: are we victims of this environment, or do we choose to take charge and do what we can to contribute to a better world. It’s times like these that shape our character.

By itself, dealing with this pathogen and its uncertain and long-term consequences is more than enough for any people to consider. Unfortunately, when COVID-19 came knocking on our door, we already faced numerous other significant crises. In this era of disruption, there is no shortage of other critical issues facing us, which have been overshadowed by the immediacy of coronavirus issues. They include: climate change; a rapidly growing gap in income and wealth; gender inequality; racism, etc.

Graduates, you are not victims. You have a role to play. It is a role many have been increasingly playing for over a decade. Witness many significant collective actions in recent years: Occupy Wall Street, which arose in 500 cities worldwide following the Great Recession; the “Arab Spring, often referred to as the Twitter Revolution; Black Lives Matter; #MeToo; Time’s Up; March for Our Lives; Never Again; Everytown for Gun Safety; the Women’s March, now a movement; OK Boomer; Youth Strike for Climate (over one million students participated); Global Climate Strike (September 2019, wherein over seven million people from 150 countries participated); etc. When we unite and gather together, we can demand change.

Scientists are studying the cause-and-effect relationship between climate change and pandemics. By itself, climate change poses an existential threat. Once a self-sustaining ecosystem, today the Earth is dying. The evidence is overwhelming: More frequent wild fires; greater and more frequent super-storms; longer periods of droughts, over-expanded geographies; rising sea levels; the warmest temperatures in recorded history; air pollution; water pollution; toxic waste.

The evening news stories have offered graphic pictures of the impact of climate change:

  • Australia, California, and the Amazon were ablaze;
  • Puerto Rico and the Bahamas were destroyed;
  • Floods have destroyed large areas from the Midwest to Bangladesh;
  • South Africa is suffering from an extreme drought, and Cape Town has a critical water shortage;
  • The Artic Sea is rapidly shrinking, and it was 70 degrees in January 2020 in Antarctica.

Despite this empirical evidence there continues to be science, economic, humanitarian, political, and crisis denial by too many. For sure, COVID-19 deserves our immediate attention, but beware what lurks behind it.

Some years ago, the late Ryuzaburo Kaku, former CEO of Canon Inc., wrote an essay in the Harvard Business Review entitled “Kyosei” (“living and working together for the common good”). Therein, he expressed particular concerned “about the imbalance between the generations, i.e. between those of us who live on Earth today, and those who will inhabit it in the future.” Graduates, we have failed you.

The teenage activist, Greta Thunberg, spoke at the United Nations last year, and said it best, “The eyes of all future generations are upon you, and if choose to fail us, we will never forgive you…This is all wrong. I shouldn’t be here. I should be back in school on the other side of the ocean. Yet you come us young people for hope. How dare you? You have stolen my dreams and my childhood with your empty words. Yet I am one of the lucky ones. People are suffering.”

COVID-19 has also called attention to health disparities in our country. While African Americans represent 13% of the US population, they are 30% of the pathogen cases testing positive. Latino communities have also been extremely hard hit. The failure to provide adequate testing in those communities points to the larger issue of racism.  We cannot fix what we cannot talk about. There are no simple discussions or solutions here. But neither can we ignore it. 

The economic consequence of the pandemic also deeply affects people of color to a greater degree. Job loss for black and brown communities, particularly those part of the gig economy, is far greater than salaried white-collar employees. This exacerbates the growing gap in income and wealth. This condition is unsustainable, and can only create a greater sense of divisiveness and class distinction in an already divided country.

Another existential threat is truth decay, and the spread of disinformation and hate. The assault on truth is an assault on trust. It breeds hatred. At a time when we need to come together to collectively address so many significant issues, leaders who intentionally contribute to lies, and perpetuate disinformation, are magnifying the damaging effects of these issues. In an age of information, where everyone knows what’s going on, this represents an inexcusable failure of leadership.

In light of all this, it is no surprise that there has been an extraordinary erosion of trust in institutions and our leaders. The secret of leadership, I have learned, is that there are no secrets.  Trust – real trust – demands truth. They are two sides of the same coin. In an era of truth decay, leaders must be honest to engender the trust necessary to lead today, and into the future.

My friend Yan Tougas posted the following on social media, quoting from Unitarian minister, Theodore Parker, speaking on slavery (1857):

“I do not pretend to understand the moral universe; the arc is a long one, my eye reaches but little ways; I cannot calculate the curve and complete the figure by the experience of sight; I can divine by conscience. But from what I see, I am sure it bends toward justice.”

Yan continues: “The arc doesn’t bend on its own. The bend is created by the courageous and persistent work of a minority, who posses a moral imagination capable of seeing a future world that is better than today’s. And so do we all have a responsibility to see the injustices around us, and to work towards its elimination, even if we never enjoy the fruits of our labor. You are not obligated to complete the work, but neither are you free to evade it.” (Rabbi Tarfon).

The pandemic is a global problem, not a national one. Climate change is a global problem. It does not belong to one nation. Truth, science, and global collaboration are critical ingredients to solving these problems. Crises can be opportunities. The pandemic is an opportunity to build a bridge between fighting COVID-19, while investing in climate change, biodiversity loss initiatives, and the new tech-enabled distance economy that awaits us.

Erich Fromm, the 20th century psychoanalyst and theologian, wrote in To Have or To Be:

”We have lost sight of the most important questions of human existence…who am I? How should I live?…We think virtues and ethical norms are arbitrary, and a matter of personal taste. It’s a battle between integrity and opportunism, the natural realm and the spiritual realm, between life and death.”

There is a Hebrew expression: tikkun olam,– “to repair the world, and build a more just, humane future.” Indeed, my work, and our work, is unfinished, incomplete.

Commencement is, by definition, “a beginning. ” We are at a turning point in human history.  What we decide today will determine the future for generations to come.  It’s time for a “new beginning. We must work together to focus on rebuilding America into a more just, humane society worthy of our children and grandchildren. Life comes with responsibility. It is our duty, individually and collectively, to work toward “repairing the world.“

Keith Darcy is President of Darcy Partners Inc., a boutique consulting firm that works with boards and top executives on a wide variety of complex governance, ethics, compliance, and reputation risk challenges. Website: Darcy.Partners

Facing Uncertainty

“I had this plan….”

People are waking up every day, stunned and dazed by a world turned upside down. The novel coronavirus has upended everyday life in ways that are unthinkable. Businesses have closed, and jobs everywhere have been lost. Friends and family are testing positive for COVID-19, and so many people are dying. The toll on human worth and dignity has been overwhelmingly harsh. There is an unresolved mourning.

In the midst of all this, any and all plans that we may have hoped for have been dashed. Life is, at best, completely uncertain. As Alvin Toffler defined the title of his 1970 best selling book, we are experiencing Future Shock, i.e. “Disorientation due to premature accelerated change.”

All crises follow a similar path. They have a beginning, a middle and, hopefully in this case, an end. The world that we left behind is never coming back. Business-as-usual is over. As medical solutions and vaccines become available – and only then – we will emerge to a completely new normal. Unfortunately, these medical solutions take time, and in the meantime we face the prospect of a second, maybe even a third wave of COVID-19.

As Alice remarked in Wonderland, “There’s no use going back to yesterday, because I was a different person then.”

Clearly, the present isn’t what it was, and the future isn’t what it used to be. We stand at the end of an age, and at the beginning of a time not yet defined. Uniquely, however, we have the opportunity to participate in defining it.

There is a familiar refrain these days. “We are all in this together.” At a time of extreme divisiveness, we are beginning to experience a new sense of unity not seen since 9/11. A common, invisible enemy is pulling us together. We applaud the first responders and front line medical people who are fighting for our lives. Food banks have sprung up everywhere. Drive-by birthday celebrations are taking place. There is a heightened sense of responsibility to family, friends, and strangers.

Although required to self-isolate, we cannot get through a crisis alone. In the days ahead we will be challenged to find new ways to create interdependencies, and search for new ways to experience community where we live and work.  It’s time we begin to plan for a future worthy of our children and grandchildren – one that is built upon a foundation integrity, dignity and human worth.

Keith Darcy is President of Darcy Partners Inc., a boutique consulting firm that works with boards and top executives on a wide variety of complex governance, ethics, compliance, and reputation risk challenges. Website: Darcy.Partners

The New (Ab)Normal

Unaltered photo by
Vladislav Grubman / CC BY-SA (https://creativecommons.org/licenses/by-sa/4.0)

Author Mary Higgins Clark once noted there are only three places in the world that begins with the article “The” – The Hague, The Vatican, and The Bronx (also known as Da Bronx). My journey began in that colorful, closely-knit bedroom borough north of Manhattan comprised mostly of lower/middle and middle class people from various ethnic backgrounds, spread among numerous apartment houses and single-family homes. I can recall the sights, sounds, and smells of my native land, like the elongated siren of the old black and green police cars, or the local buses spewing smoke as they departed from their stops. No matter where I go, they stay synonymous with a place called home.

Today, New York is silent. Silence is the complete absence of sound. The novel coronavirus has brought about a deafening silence as we shelter-in-place. But more disturbingly, it has silenced daily life in this bustling city

In New York City, the sidewalks are almost as empty as the streets. Among the few sounds we hear are in the morning, when there is a change of shifts at the city’s hospitals, and at the police and fire stations. But at 7:00PM, the silence is broken with gratitude, as people everywhere open their windows to bang pots and pans in recognition of these same brave people who are giving so much to help.

The quiet in New York is exacerbated by the face masks we wear. The masks cover our faces so we don’t pass on the virus. They also conceal from view the sheer terror we are experiencing. The mask, however, is especially troubling when the behavior of some leaders muffles the message when being less than truthful.

Some years back I visited Consumer Reports headquarters and learned about something called anechoic chamber. It is a place that completely absorbs reflections of sound. It is a place so quiet that you can hear your heart, lungs, stomach, and even the blood coursing through your veins. All sound is traveling away from the source.

At a time when there is so much pain and suffering, it is important for leaders to listen to their inner voice. In the silence of our personal anechoic chamber we can hear the deep moaning in the world, and better reflect on ways to address what’s needed. Our humanity depends upon it.

Keith Darcy is President of Darcy Partners Inc., a boutique consulting firm that works with boards and top executives on a wide variety of complex governance, ethics, compliance, and reputation risk challenges. Website: Darcy.Partners

Challenges, Risks, and Potential Liabilities for CCOs

Photo by Philipp Birmes on Pexels.com

Without question risks in today’s world are rising, as are the expectations of enforcement authorities. In a perfectly transparent world, there are no secrets, and there is no place to hide. CCOs are on the front line of managing organizational risk and preserving reputation capital. In this environment, the challenges, risks and potential liabilities for CCOs are growing.

Read the full article below:

A Defining Moment: Dealing With Disruption

For most of my career, my routine was predictable. I awakened early, well before dawn. After showering and getting dressed, I’d pour a cup of coffee into my travel mug, get into my car, and begin the 50 mile drive to my office in lower Manhattan. Upon arrival I would check my in-box, and review my calendar for calls and meetings for that day. Our CEO would arrive some 30 minutes later with his coffee from Au Bon Pain, and we would discuss outcomes from the day before, and mutual priorities for the bank facing us. We would engage with various stakeholders, and revisit at the end of the day to discuss the significant events we experienced.

Today, millions of people wake up without jobs. Some have been given limited severance, many others none. Some are furloughed and retain their health insurance, but most have none. And, perhaps most frightening of all – there is no end to this crisis in sight.

For the more fortunate who have retained their jobs, most are sheltered-in-place. Every day feels like Groundhog Day. The kids are distance learning, feel a diminished sense of parental attention, and a disconnect from their peers. They spend their spare time torturing one another. Tension between spouses rise, often dramatically.

For everyone, there is a deep anxiety, indeed terror, at the loss of a predictable future.

Anything that resembled a routine is gone. “Business-as-usual” no longer exists, and is unlikely to ever return. The starting point for leaders is to acknowledge the brutal truths that everyone is experiencing. In an era of truth decay, leaders must be honest to engender the trust necessary to lead today, and into the future.  Trust, real trust, demands truth – they are two sides of the same coin. Leaders cannot spin the truth. In an age of transparency, everyone knows what’s going on.

Given that we are all shuttered-in-place, there has been a profound loss of touch. Michael Osterholm, MD, a world-renowned infectious disease expert, favors the term “physical distance” versus social distance. This is particularly important for leaders, who need to be on the front line, fully engaged with all stakeholders. While required to be physically distant, they cannot afford to be socially distant. 

The life-threatening novel coronavirus, combined with a global economic collapse, pose formidable existential questions for leaders.  We are in the midst of a complete and global disruption, i.e. “a break in the normal course of activities” according to Merriam-Webster. In this era, leaders everywhere will be judged more for who they are, and the values that they represent, than for what they do.

Keith Darcy is President of Darcy Partners Inc., a boutique consulting firm that works with boards and top executives on a wide variety of complex governance, ethics, compliance, and reputation risk challenges. Website: Darcy.Partners

A Defining Moment

No living generation has ever experienced a pandemic. When the novel coronavirus knocked on our door, there was no playbook to rely on. We are in virgin territory, blindly Brailleing our way into a very uncertain future. As much as we pray for a quick resolution to this crisis – sufficient and reliable testing and tracing devices, a vaccine sooner than later, perhaps – the brutal reality is that the direct and indirect consequences of the COVID-19 crisis will be with us for a very long time. The life-threatening consequences of this disease, its horrific impact on our healthcare systems, and the extraordinary and overwhelming damage to our economy are beyond our capacity to absorb.

For leaders everywhere, this is a defining moment.

Many of us experienced another defining moment. On September 11, 2001, I looked out my office window in lower Manhattan and watched as a jet flew across the Hudson River straight toward me, turn left, and slam into the south tower of The World Trade Center. That day, and all its aftermath, is indelibly etched into my soul. My brother’s name is carved into the stone of the Weeping Pools at 66N. The memories of that day remain too vivid, too painful. A cycle of fear, panic, and anxiety hit people everywhere, both near and far.

The pandemic we are in the midst of is, however, not comparable to 9/11, which was confined in time. Much as we wish today to go back to business as usual, to return to the jobs we lost, the ballgames, concerts, industry conferences, and dinners out that we miss, our ability to gather together will be severely limited for an extended period of time, perhaps long into the future.  And unfortunately, as time moves forward, everyone will know someone who tested positive, or someone who died.

Almost every crisis has a beginning, middle, and end. The end of the impact of this pandemic is not yet in sight.

However, I know from my experience on 9/11 that how leaders treat their employees during this crisis will forever define their company’s culture, and how leaders treat all stakeholders will forever define their company’s brand. In the aftermath of September 11th, the only thing that mattered to me was to care for the physical and emotional safety of my employees. What else could be more important? In the end, we only have each other.

For leaders, there are no easy decisions going forward. Our fight for survival – for our physical and economic health – is forcing us to make existential ethical choices. The pain caused by COVID-19 is overwhelming, and palpable. Ethics is how we choose, and how we respond to everyday decisions that confront us. We express our choices both through our actions, as well as our inactions, i.e. what we do, as well as don’t do. Words without actions are an empty chalice. In the midst of uncertainty and anxiety, the choices we make in the days ahead will define us as individuals, organizations, and as a society – forever.

Keith Darcy is President of Darcy Partners Inc., a boutique consulting firm that works with boards and top executives on a wide variety of complex governance, ethics, compliance, and reputation risk challenges. Website: Darcy.Partners

Keith Darcy: How Boards Can Raise the Bar on Ethics and Compliance

A symbiotic relationship between ethics and compliance can help companies deliver shareholder value and mitigate risks. Keith Darcy, independent senior advisor to Deloitte & Touche LLP’s Governance, Regulatory & Risk Strategies enterprise compliance practice, discusses how boards can guide an organization’s ethics and compliance efforts in light of heightened regulatory scrutiny and emerging 

threats. Mr. Darcy is the former executive director of the Ethics & Compliance Officer Association, and has been the CEO and served on boards of various financial services institutions. 

Download the full article below.

Whistleblower Programs: Who Should Be in Charge?

Whistleblower programs that operate outside of an ethics and compliance function can expose an organization to a set of risks that can ultimately impact reputation, according to Keith Darcy, an independent senior advisor to Deloitte & Touche LLP, and Maureen Mohlenkamp, a principal with Deloitte LLP. Putting in place rigorous protocols and procedures from the start, especially those involving helpline and hotline communications and case follow-ups, and applying them consistently, is essential.

Read full article via the Wall Street Journal here.

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