Publications

March 2018 (Revised April 2018)
Case

Designing a Compliance Program at AB InBev

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

Forthcoming
Article

Sending a Message: An Empirical Assessment of Responses to Punitive and Non-punitive Compliance Messaging Strategies

By: Jodi L. Short, Michael W. Toffel, Elizabeth A. Keenan and Melissa Ouellet

Regulators operate in an increasingly hostile political environment. The U.S. Supreme Court is ramping up efforts to curtail the authority of administrative agencies. The second election of Donald Trump to the presidency has unleashed a torrent of anti-regulatory... View Details

Keywords: Field Experiment; Compliance; Compliance Programs; Compliance Policies; Regulatory Enforcement; Environmental Regulation; Environmental Policy; Government Experimentation; Governance Compliance; Government Administration; Governing Rules, Regulations, and Reforms; Business and Government Relations; Construction Industry; Public Administration Industry; California; United States

SSRN

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

Register to Read

May 2018 (Revised January 2019)
Teaching Note

Designing a Compliance Program at AB InBev

Teaching Note for HBS No. 118-071. View Details

Keywords: Governance; Crime and Corruption; Governance Compliance; Consumer Products Industry; Africa; Europe; India; North America

13 May 2014
News

More Evidence That Compliance & Ethics Education Clash

Article

Paper Versus Practice: A Field Investigation of Integrity Hotlines

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

Register to Read

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

January 2019
Case

Accenture's Code of Business Ethics

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

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

SSRN

September 2022 (Revised June 2025)
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

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

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

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

20 Mar 2018
First Look

First Look at New Research and Ideas, March 20, 2018

the duration and size of price changes using scraped data collected from 181 retailers in 31 countries. Publisher's link: https://www.hbs.edu/faculty/Pages/item.aspx?num=52241 March–April 2018 Harvard Business Review Why Compliance View Details

Keywords: Sean Silverthorne

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

September 2009
Article

Virtue out of Necessity? Compliance, Commitment and the Improvement of Labor Conditions in Global Supply Chains

By: Akshay Mangla, Richard Locke and Matthew Amengual

Private, voluntary compliance programs, promoted by global corporations and nongovernmental organizations alike, have produced only modest and uneven improvements in working conditions and labor rights in most global supply chains. Through a detailed study of a major... View Details

Keywords: Working Conditions; Ethics; Supply Chain; Governance Compliance; Globalization