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Publications

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    • All HBS Web  (166)
      • Faculty Publications  (26)

      Compliance ProgramsRemove Compliance Programs →

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      • July 2023 (Revised October 2024)
      • Case

      Revenue Recognition at Stride Funding: Making Sense of Revenues for a Fintech Startup

      By: Paul M. Healy and Jung Koo Kang
      The case explores the challenges of revenue recognition and financial reporting for Stride Funding (Stride), a fintech startup that has disrupted the student loan market. Stride leveraged proprietary machine learning and financial models to underwrite alternative... View Details
      Keywords: Revenue Recognition; Financial Reporting; Entrepreneurial Finance; Business Startups; Growth and Development Strategy; Governance Compliance; Accrual Accounting; Financial Services Industry; United States
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      Healy, Paul M., and Jung Koo Kang. "Revenue Recognition at Stride Funding: Making Sense of Revenues for a Fintech Startup." Harvard Business School Case 124-015, July 2023. (Revised October 2024.)
      • September 2022 (Revised January 2023)
      • Case

      York Capital CLOs and WorldStrides International

      By: Victoria Ivashina and William Vrattos
      The case follows the debt restructuring of WorldStrides International, a travel program provider in the education market, after the onset of COVID-19. The pandemic severely impacted the travel industry, creating challenges for many companies like WorldStrides, which... View Details
      Keywords: COVID-19 Pandemic; Debt Restructuring; CLO; Compliance; Debt Securities; Financing and Loans; Decision Making; Travel Industry; Education Industry
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      Ivashina, Victoria, and William Vrattos. "York Capital CLOs and WorldStrides International." Harvard Business School Case 223-034, September 2022. (Revised January 2023.)
      • Article

      Cash-for-Information Whistleblower Programs: Effects on Whistleblowing and Consequences for Whistleblowers

      By: Aiyesha Dey, Jonas Heese and Gerardo Pérez Cavazos
      Cash-for-information whistleblower programs have gained momentum as a regulatory tool to enforce corporate misconduct. Yet, little is known about how financial incentives affect whistleblowers’ decisions to report potential misconduct to authorities. Similarly, there... View Details
      Keywords: Corporate Misconduct; Whistleblowers; Financial Incentives; Ethics; Governance Compliance; Lawsuits and Litigation
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      Dey, Aiyesha, Jonas Heese, and Gerardo Pérez Cavazos. "Cash-for-Information Whistleblower Programs: Effects on Whistleblowing and Consequences for Whistleblowers." Harvard Law School Forum on Corporate Governance (June 10, 2021).
      • Article

      Manage the Suppliers That Could Harm Your Brand: Know When to Avoid, Engage, or Drop Them

      By: Jodi L Short and Michael W. Toffel
      The pandemic has placed a new spotlight on working conditions in factories that supply global companies. To avert problems, firms often impose codes of conduct on their suppliers and perform audits to assess compliance. Do these measures help identify unethical... View Details
      Keywords: Auditing; Agency Cost; Quality And Safety; Quality Management System; Quality Management; Unions; Environmental Management; Globalization; Goods and Commodities; Governance; Labor; Labor Unions; Wages; Working Conditions; Operations; Supply Chain; Safety; Quality; China; Bangladesh; Asia; Pakistan
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      Short, Jodi L., and Michael W. Toffel. "Manage the Suppliers That Could Harm Your Brand: Know When to Avoid, Engage, or Drop Them." Harvard Business Review 99, no. 2 (March–April 2021).
      • Article

      Returnable Reciprocity: Returnable Gifts Are More Effective than Unreturnable Gifts at Promoting Virtuous Behaviors

      By: J.J. Zlatev and Rogers, T.
      Increasing virtuous behaviors, such as initiating healthy habits, is an important goal for policymakers and social scientists. To promote compliance with requests to perform virtuous behaviors, we study “returnable reciprocity.” Whereas traditional reciprocity involves... View Details
      Keywords: Nudges; Reciprocity; Want-should Conflicts; Wellness; Health; Behavior; Change; Well-being
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      Zlatev, J.J., and Rogers, T. "Returnable Reciprocity: Returnable Gifts Are More Effective than Unreturnable Gifts at Promoting Virtuous Behaviors." Organizational Behavior and Human Decision Processes 161, Supplement (November 2020): 74–84.
      • November 2020
      • Article

      When the Boss Comes to Town: The Effects of Headquarters' Visits on Facility-Level Misconduct

      By: Jonas Heese and Gerardo Pérez Cavazos
      We study the effects of headquarters’ visits on facility-level misconduct. We use the staggered introduction of airline routes to identify exogenous travel-time reductions between headquarters and facilities and test whether such reductions affect facility-level... View Details
      Keywords: Corporate Misconduct; Visits By Management; Flight Routes; Control Systems; Compliance Programs; Performance Pressure; Business or Company Management; Management Systems; Governance Controls; Governance Compliance; Performance Expectations
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      Heese, Jonas, and Gerardo Pérez Cavazos. "When the Boss Comes to Town: The Effects of Headquarters' Visits on Facility-Level Misconduct." Accounting Review 95, no. 6 (November 2020): 235–261.
      • August 2020
      • Article

      Improving Working Conditions in Global Supply Chains: The Role of Institutional Environments and Monitoring Program Design

      By: Jodi L. Short, Michael W. Toffel and Andrea R. Hugill
      Activism seeking to improve labor conditions in global supply chains has led many transnational corporations to adopt codes of conduct and monitor suppliers for compliance. Drawing on thousands of audits conducted by a major social auditor, we identify structural... View Details
      Keywords: Monitoring; Supplier Relationship; Sustainability; Sustainability Management; Sustainable Operations; Sustainable Supply Chains; NGO; Operations; Supply Chain Management; Governance Compliance; Corporate Social Responsibility and Impact; Global Range; Working Conditions
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      Short, Jodi L., Michael W. Toffel, and Andrea R. Hugill. "Improving Working Conditions in Global Supply Chains: The Role of Institutional Environments and Monitoring Program Design." ILR Review 73, no. 4 (August 2020): 873–912.
      • Article

      Paper Versus Practice: A Field Investigation of Integrity Hotlines

      By: Eugene Soltes
      In an effort to motivate firms to more rapidly detect potential misconduct, legislators, regulators, and enforcement agencies incentivize firms to have integrity or “whistleblowing” hotlines. These hotlines provide individuals an opportunity to report alleged... View Details
      Keywords: Hotlines; Compliance Programs; Corporate Misconduct; Governance Compliance; Programs; Performance
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      Soltes, Eugene. "Paper Versus Practice: A Field Investigation of Integrity Hotlines." Journal of Accounting Research 58, no. 2 (May 2020): 429–472.
      • January 2019
      • Case

      Accenture's Code of Business Ethics

      By: Eugene Soltes
      Leaders of Accenture’s compliance and ethics program are seeking to design a new code of business ethics for its global workforce of over 400,000 employees. The case explores the decision-making process that went into the design process and ultimately how they created... View Details
      Keywords: Code Of Conduct; Compliance; Ethics; Law; Leadership; Governance Compliance
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      Soltes, Eugene. "Accenture's Code of Business Ethics." Harvard Business School Case 119-049, January 2019.
      • Article

      Evaluating the Effectiveness of Corporate Compliance Programs: Establishing a Model for Prosecutors, Courts, and Firms

      By: Eugene F. Soltes
      When prosecutors, courts, and regulators make charging and sentencing decisions, they must evaluate whether firms have effective compliance programs. Such evaluations are difficult because of the challenges associated with measuring effectiveness. Notably, these... View Details
      Keywords: Corporate Governance; Governance Compliance; Performance Effectiveness; Performance Evaluation
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      Soltes, Eugene F. "Evaluating the Effectiveness of Corporate Compliance Programs: Establishing a Model for Prosecutors, Courts, and Firms." NYU Journal of Law & Business 14, no. 3 (Summer 2018): 965–1011.
      • May 2018 (Revised January 2019)
      • Teaching Note

      Designing a Compliance Program at AB InBev

      By: Eugene Soltes
      Teaching Note for HBS No. 118-071. View Details
      Keywords: Governance; Crime and Corruption; Governance Compliance; Consumer Products Industry; Africa; Europe; India; North America
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      Soltes, Eugene. "Designing a Compliance Program at AB InBev." Harvard Business School Teaching Note 118-126, May 2018. (Revised January 2019.)
      • March 2018 (Revised April 2018)
      • Case

      Designing a Compliance Program at AB InBev

      By: Eugene Soltes
      Compliance programs help companies align the interests and behavior of employees with external expectations and regulation. The case discusses how AB InBev, a major brewer, developed its compliance program. View Details
      Keywords: Governance; Crime and Corruption; Governance Compliance; Consumer Products Industry; Africa; Europe; India; North America
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      Soltes, Eugene. "Designing a Compliance Program at AB InBev." Harvard Business School Case 118-071, March 2018. (Revised April 2018.)
      • Article

      Why Compliance Programs Fail: And How to Fix Them

      By: Hui Chen and Eugene Soltes
      Firms spend millions of dollars annually on whistle-blower hotlines, training, and other efforts to ensure adherence to laws, regulations, and company policies. Yet malfeasance remains entrenched in the corporate world. Why? Too many firms treat compliance as a... View Details
      Keywords: Governance Compliance; Programs; Employees; Training; Performance Effectiveness; Measurement and Metrics
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      Chen, Hui, and Eugene Soltes. "Why Compliance Programs Fail: And How to Fix Them." Harvard Business Review 96, no. 2 (March–April 2018): 116–125.
      • August 2015 (Revised October 2017)
      • Case

      Turnaround at Norsk Gjenvinning (A)

      By: George Serafeim
      Erik Osmundsen, CEO of Norsk Gjenvinning (NG), had initiated a program to strenghten corporate governance, eliminate corruption and improve compliance, and as a result the company had experienced a turnover of almost half of its top 70 line managers and strained... View Details
      Keywords: Change Leadership; Governance; Compliance; Waste Management; Environmental Impact; Social Responsibility; Industry Regulation; Regulatory Enforcement; Turnaround; Turn Around Management; Corruption; Leading Change; Change Management; Crime and Corruption; Governance Compliance; Wastes and Waste Processing; Industrial Products Industry; Norway; Scandinavia; Europe
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      Serafeim, George, and Shannon Gombos. "Turnaround at Norsk Gjenvinning (A)." Harvard Business School Case 116-012, August 2015. (Revised October 2017.)
      • 2012
      • White Paper

      Robust Enforcement Should Complement Voluntary Regulation

      By: Jodi L. Short and Michael W. Toffel
      Spurred by the anti-regulation movement that started in the 1970s, voluntary self-regulation programs have emerged in many regulatory agencies, seeking to increase cooperation between government and industry to achieve greater and more cost-effective compliance.... View Details
      Keywords: Governance Compliance; Business and Government Relations
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      Short, Jodi L., and Michael W. Toffel. "Robust Enforcement Should Complement Voluntary Regulation." Georgetown University Economic Policy Vignette, September 2012.
      • January 2012
      • Background Note

      Legal Compliance Programs

      By: Lynn S. Paine and Lara Adamsons
      Keywords: Governance Compliance; Programs
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      Paine, Lynn S., and Lara Adamsons. "Legal Compliance Programs." Harvard Business School Background Note 312-111, January 2012.
      • September 2011
      • Article

      A Global Leader's Guide to Managing Business Conduct

      By: Lynn S. Paine, Rohit Deshpandé and Joshua D. Margolis
      An extensive global survey by three Harvard Business School professors finds that employees agree on core standards of corporate behavior. But meeting those standards will require new approaches to managing business conduct. The compliance and ethics programs of most... View Details
      Keywords: Leadership; Management; Ethics; Cross-Cultural and Cross-Border Issues; Globalized Firms and Management; Standards; Corporate Accountability; Corporate Governance
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      Paine, Lynn S., Rohit Deshpandé, and Joshua D. Margolis. "A Global Leader's Guide to Managing Business Conduct." Harvard Business Review 89, no. 9 (September 2011). (Online edition.)
      • August 2011
      • Article

      Coming Clean and Cleaning Up: Does Voluntary Self-Reporting Indicate Effective Self-Policing

      By: Michael W. Toffel and Jodi L. Short
      Regulatory agencies are increasingly establishing voluntary self-reporting programs both as an investigative tool and to encourage regulated firms to commit to policing themselves. We investigate whether voluntary self-reporting can reliably indicate effective... View Details
      Keywords: Environmental Sustainability; Governing Rules, Regulations, and Reforms; Programs; Governance Compliance; Corporate Disclosure; Law Enforcement
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      Toffel, Michael W., and Jodi L. Short. "Coming Clean and Cleaning Up: Does Voluntary Self-Reporting Indicate Effective Self-Policing." Journal of Law & Economics 54, no. 3 (August 2011): 609–649.
      • Article

      The Causes and Consequences of Industry Self-Policing

      By: Jodi L. Short and Michael W. Toffel
      Innovative regulatory programs are encouraging firms to police their own regulatory compliance and voluntarily disclose, or "confess," the violations they find. Despite the "win-win" rhetoric surrounding these government voluntary programs, it is not clear why... View Details
      Keywords: Corporate Disclosure; Governance Compliance; Law Enforcement; Policy; United States
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      Short, Jodi L., and Michael W. Toffel. "The Causes and Consequences of Industry Self-Policing." Yale Economic Review 4, no. 2 (Summer 2008).
      • May 2008
      • Article

      Coerced Confessions: Self-Policing in the Shadow of the Regulator

      By: Jodi L. Short and Michael W. Toffel
      As part of a recent trend toward more cooperative relations between regulators and industry, novel government programs are encouraging firms to monitor their own regulatory compliance and voluntarily report their own violations. In this study, we examine how regulatory... View Details
      Keywords: Governance Compliance; Law Enforcement; Corporate Disclosure; Governing Rules, Regulations, and Reforms; Environmental Sustainability; Programs; Power and Influence; Organizations; Decisions; Business and Government Relations; United States
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      Short, Jodi L., and Michael W. Toffel. "Coerced Confessions: Self-Policing in the Shadow of the Regulator." Journal of Law, Economics & Organization 24, no. 1 (May 2008): 45–71.
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