Here are our top 10 compliance movies - a roll call of some of the greatest films with a compliance theme. Most importantly, they are all inspired by real events. These salutary tales (well, mostly) are a unique way to understand compliance.
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They are not in any particular order, but each covers a key compliance area. And if you think we've missed your own favourite, let us know!
- Compliance (2012)
- Bombshell (2019)
- Philadelphia (1993)
- The Wolf of Wall Street (2013)
- Serpico (1973)
- The Great Hack (2019)
- Erin Brockovich (2000)
- The Whistleblower (2010)
- The Informant (2009)
- Rogue Trader (1999)
We've also added our pick of the best' true story' compliance movies of the last couple of years at the end of this blog.
We'll be adding our pick of those 'allegedly' fictional compliance movies soon!
For those preferring the written form, we've also compiled a list of the best governance, risk and compliance books too.
Our pick of the top 10 compliance movies
1. Compliance (2012)
Starring: Dreama Walker, Ann Dowd
Based upon a phone call scam in Kentucky, a caller posing as a police officer convinced a restaurant manager to carry out unlawful and intrusive procedures on an employee.
In the film, a fast-food worker is accused of theft and put through a demeaning ordeal as her boss, at the direction of a phone caller who says he's a policeman, subjects her to increasingly extreme forms of interrogation.
- Watch out for signs of fraudsters attempting to compromise or use a stolen identity. Callers who ask to confirm personal details that they should have already, callers who request a significant transaction soon after changing their personal details, and callers who demand the return of a deposit or a rushed purchase without consideration of penalties and charges
- Take extra care to prevent customers and colleagues' information from being compromised. For example, be alert to phishing emails or unusual activity on your computer that suggests it may be infected by malware.
- Avoid giving out personal information, date of birth or passwords even after a customer has passed a security questionnaire.
- Report any knowledge, suspicions or concerns you have about identity theft or fraud immediately to your manager or via our whistleblowing hotline
2. Bombshell (2019)
Starring: Charlize Theron, Nicole Kidman and Margot Robbie
Bombshell is based upon employees' accounts trying to expose sexual harassment at Fox News.
Following Gretchen Carlson getting fired (ostensibly for supporting a weapons ban), she pursued a discrimination lawsuit against Roger Ailes (the then Fox CEO). After being defeated, Roger Ailes is fired by Rupert Murdoch. Ailes settles Carlson's lawsuit for $20 million and an apology from Fox, but with a gagging order.
Eventually, Fox paid sexual harassment victims a total of $50 million. In comparison, Ailes and another Fox employee Bill O'Reilly received $65 million in severance.
- Do everything possible to create a positive working environment where everyone is valued and treated with respect.
- Have grievance procedures in place to ensure that any incidents of sexual harassment are taken seriously and properly investigated.
- Make it clear in your company's Code of Conduct and policies that sexual harassment is unacceptable and will not be tolerated.
- Protect anyone who complains about sexual harassment from retaliation or victimisation.
- Review your corporate culture regularly to ensure that you don't condone behaviour that borders on sexual harassment and prevent abuse by people in positions of power or authority.
- Offer different reporting mechanisms and empower people to speak out if they experience harassment or witness anyone else being subjected to it.
3. Philadelphia (1993)
Starring: Tom Hanks and Denzel Washington
Philadelphia tells the story of Andrew Beckett, a lawyer at a large corporate law firm who is gay and has developed AIDS.
When he is suddenly fired by the firm's partners, Beckett brings about a wrongful dismissal suit based on discrimination related to his sexuality and AIDS diagnosis.
Philadelphia was one of the first mainstream Hollywood films to acknowledge HIV/AIDS, homosexuality and homophobia.
- Any decision to dismiss any employee should be based solely on merit and performance. No other criteria should be used to reach a decision.
- Some cases of dismissal are considered 'automatically unfair' regardless of reasonableness, such as dismissal due to pregnancy, trade union membership, or based on one of the nine protected characteristics.
- Keep in mind that all employees have the right not to be dismissed unfairly and can make a complaint to an Employment Tribunal.
4. The Wolf of Wall Street (2013)
Starring: Leonardo Di Caprio, Margot Robbie and Jonah Hill
Based on the life and times of Jordan Belfort, The Wolf of Wall Street depicts his rise from a junior Wall Street stockbroker to his eventual imprisonment.
In the 1990s, Belfort founded brokerage firm Stratton Oakmont and made a huge fortune defrauding wealthy investors out of millions, all while enjoying a hedonistic lifestyle. However, the SEC and the FBI eventually cotton onto Belfort's trading schemes and work to bring down his empire.
Belfort ended up serving 22 months in prison after pleading guilty in 1999 to securities fraud and money laundering as part of a scheme that cost investors approximately $200m.
- Act with integrity and honesty in all your professional dealings, and take extra care not to abuse your position and manage any conflicts of interest.
- Watch out for the tell-tale signs of fraud.
- Don't become an unwitting accomplice to unscrupulous third parties, employees, customers, suppliers or others in acts of fraud.
- Review your anti-fraud systems and controls regularly to ensure that they operate effectively and identify any improvements needed.
- Report any knowledge or suspicions of fraud to the relevant authorities immediately.
- Don't make recommendations or induce others to deal while in possession of inside information.
5. Serpico (1973)
Starring: Al Pacino, John Randolph and Jack Kehoe
Serpico is a biographical-crime film adapted from a book about Frank Serpico, an honest detective struggling to deal with corruption within the NYPD during his 11 years of service.
Unlike the rest of the force, Serpico refuses to take bribes. As a result, other officers shunned him putting his life in danger. With his superiors turning a blind eye to department-wide misconduct, Serpico decides to blow the whistle on his colleagues' corruption.
The actions of Frank Serpico resulted in the formation of the Knapp Commission, whom he testified before and resulted in criminal indictments against corrupt police officials. Nearly 50 years on, corruption still dogs the NYPD.
- Don't offer or accept cash or anything of value in return for improper performance of any function.
- Comply with the expected standards for initial and ongoing due diligence of clients and third parties.
- Have clear gifts, hospitality and expenses policies for guidance on what it is ok to offer and accept and how any issues should be handled.
- Never make facilitation payments to secure or speed up the performance of a function by a government official.
- Be transparent and report any knowledge or suspicion of bribery immediately.
6. The Great Hack (2019)
Starring: Carole Cadwalladr, David Carroll and Brittany Kaiser
This documentary takes a look at the 2015 Cambridge Analytica scandal. The UK-based political consulting firm began working on Ted Cruz's campaign to win the 2016 US Republican nomination. The firm had used Facebook as a means for 'political-voter surveillance' through the collection of user data points.
The illicit harvesting of personal data by Cambridge Analytica was first reported in December 2015 by Harry Davies. Independent investigations into data mining, along with whistleblower accounts of the firm's impact on Brexit, led to a scandal over the influence of social media in political elections.
Facebook founder Mark Zuckerberg even had to testify before several committees of the United States Congress regarding data privacy.
- Ensure that you protect personal data against unauthorised or unlawful processing and accidental loss, destruction or damage.
- Don't conceal or cover up data losses or breaches. Report mistakes and violations promptly so that damage to the data subject, your company and yourself can be limited.
- Don't start collecting personal data or using it for different purposes without first checking with your company's Data Protection Officer (DPO).
- Comply with procedures to ensure accuracy and observe the retention periods of personal data.
7. Erin Brockovich (2000)
Starring: Julia Roberts, Albert Finney and Aaron Eckhart
Julia Roberts plays the titular character, a single mother who becomes a legal assistant. While looking at a case involving the Pacific Gas and Electric Company (PG&E), she discovers that they're poisoning a town's water supply with carcinogenic hexavalent chromium.
Despite having no legal, medical or scientific training, Brockovich succeeds in securing a $333m (£240m) settlement from PG&E for over 600 plaintiffs who alleged injury from drinking contaminated water.
Even today, the US is going through something of a 'water crisis'. An investigation by The Guardian revealed that US tap water contained alarming levels of arsenic, lead and toxic chemicals.
- Do everything possible to get rid of any barriers to whistleblowing in order to increase reporting.
- Be aware of what drives and inhibits whistleblowers when making disclosures.
- Ensure that your policy focuses on equitable treatment. Never tolerate any detrimental treatment of whistleblowers, and make sure that those accused of wrongdoing by whistleblowers are also treated fairly.
- Make sure that the identity of whistleblowers is never disclosed.
8. The Whistleblower (2010)
Starring: Rachel Weisz, Monica Bellucci and Vanessa Redgrave
Inspired by the story of Kathryn Bolkovac, a police officer recruited as a United Nations peacekeeper for DynCorp International in post-war Bosnia and Herzegovina in 1999.
While serving there, she uncovered a sex trafficking ring serving and facilitated by DynCorp employees, with international peacekeepers turning a blind eye. Although she alerted the relevant authorities, Bolkovac was fired and forced out of the country. Eventually, she took the story to BBC News in the UK and won a wrongful dismissal lawsuit against DynCorp.
Modern slavery is a scourge that unfortunately still persists, with the ILO estimating there are 40 million people in forced labour.
- Look out for signs of modern slavery and develop indicators of labour trafficking or exploitation.
- Always conduct due diligence on all clients, suppliers and third parties. Make sure that you 'know the chain'.
- Never confront anyone suspected of involvement in modern slavery. You may put potential victims at greater risk and valuable evidence may be lost.
- If you have concerns or see anything suspicious, report it immediately. People's lives may depend on it!
9. The Informant (2009)
Starring: Matt Damon, Scott Bakula and Joel McHale
Mark Whiteacre is an executive at Archer Daniels Midland (ADM), who blows the whistle on his company's price-fixing to the FBI. ADM executives (including Whitacre himself) routinely met with competitors to fix the price of lysine, an additive used in the commercial livestock industry.
While Whiteacre tried to do a good deed by reporting his company's misconduct, he ended up shining a light on his own criminality in a bizarre twist of fate. During the FBI's investigation, it emerges that while informing his colleagues, Whiteacre was also embezzling money from ADM.
Despite approaching the FBI to blow the whistle, Whiteacre ironically ended up spending nine years in prison, getting a heftier sentence than his fellow executives (who only got three years).
- Don't discuss or enter agreements with competitors. That includes prices, production volumes, intended bids or agreeing to share markets or customers.
- Don't place price, territorial or online sales restrictions on suppliers or distributors. If you need to do this, get advice from your legal team first.
- Be careful not to act in ways that restrict competition in any market. By exploiting your dominant position, e.g. refusing to supply, prohibiting discounting, imposing exclusive obligations or entering 'pay-for-delay' deals.
- Never discuss commercially sensitive information with competitors, suppliers or retailers. That includes RRPs, future pricing plans and promotions.
- Report any suspicion of competition law violation immediately. This is vital because under leniency rules, the first to report to the authorities can often escape prosecution.
10. Rogue Trader (1999)
Starring: Ewan McGregor and Anna Friel
Ewan McGregor takes the lead in the true story of Nick Leeson, a trader at Barings Bank. He hid huge losses whilst the powers-that-be back in London seemed asleep at the wheel. The £800 million losses he built up contributed to Barings going bankrupt. Leeson was sentenced to six and a half years in jail.
- Ensure you have restrictions in place to control the trading of instruments. In terms of which desks can trade instruments. When staff can trade instruments, and how much in a given period.
- Ensure trading limits are carefully set and monitored. To protect the company and to satisfy regulators.
- Never try to cover up any losses you or your employees have made. Doing so may cause the problem to spiral out of control.
The best new compliance movies
Starring: Michael Keaton, Amy Ryan and Stanley Tucci
Worth tackles the thorny issue of compensation to victims. In this instance, relations of those who perished in the 9/11 terrorist attacks.
Not only does it cover issues of Government and corporate liability, but also equality in terms of whom may be eligible for compensation. These issues may occur in the workplace when breaches of equality, health or whistleblowing. And in terms of impact, assessments also apply to GDPR breaches.
The Laundromat (2019)
Starring: Meryl Streep, Gary Oldman and Antonio Banderas
The Panama Papers were a giant leak of more than 11.5 million financial and legal records that exposed a system that enables crime, corruption and wrongdoing, hidden by secretive offshore companies. The name derives from the source of the documents, an offshore law firm based in Panama.
The records were obtained from an anonymous source by the German newspaper Süddeutsche Zeitung, which shared them with the International Consortium of Investigative Journalists (ICIJ). The ICIJ then shared them with a large network of international partners, including the Guardian and the BBC.
The Laundromat is a three-stranded, partly fictionalised account of the impact that such shell corporations, tax havens, fraud and money laundering have./p>
Dark Waters (2019)
Starring: Mark Ruffalo, Anne Hathaway and Tim Robbins
Darks Waters tells the story of Robert Bilott's case against the chemical manufacturing corporation DuPont after they contaminated a town with unregulated chemicals.
The company is the affected town's largest employer, creating mixed reactions amongst the local residents when a legal firm. Over almost a decade, the case drags on whilst monitoring takes place. Eventually, the Teflon manufacturing company settled with more than 35,000 affected residents to the tune of $671m.
Official Secrets (2019)
Starring: Keira Knightley, Matt Smith and Ralph Fiennes
Official Secrets focuses on the case of whistleblower Katharine Gun, the source of a leak exposing an illegal spying operation by American and British intelligence services. The memo detailed a plan to gauge sentiment, then potentially blackmail UN diplomats tasked to vote on a resolution regarding the 2003 invasion of Iraq.
After much press coverage, a GCHQ investigation identifies the source of the leak, leading to the arrest of the whistleblower. Her defence hinges on the premise that she was acting in defence of her country to prevent an illegal war. This literally becomes a moot point when the Crown Prosecution decides to drop the case on the day of the trial.
Many have got in touch to say they are disappointed that their favourite film didn't make this list. Often, some films have maintained that they are purely fiction for legal reasons. Come back in Oscar season, and we will be addressing that gap. So if you have any suggestions, you know where we are!
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