Building and Maintaining an Ethical Culture Program within the Organization

Level: Advanced
Runtime: 59 minutes
Recorded Date: September 26, 2019
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  • The Building Blocks of an Ethical Culture
  • Types of Ethical Culture
  • The Importance of an Effective Ethics Program
  • Training in an Ethical Environment
  • Internal Reporting
  • Case Study
  • Drafting Effective & Ethical Interview Questions
  • Best Practices for Internal Investigations
  • Q & A
Runtime: 1 hour
Recorded: September 26, 2019


In addition to ensuring compliance to various regulations, developing and updating an organizational ethics program helps firms to proactively identify risks and enforce ethical behavior. Also, current and prospective investors often evaluate a firm’s compliance programs and evaluate the effectiveness of the ethical culture and practices throughout the organization as part of their due diligence. As such, GCs and COOs are more involved in the firm’s strategic initiatives.

During this session, we will discuss the traits of strong ethics programs, what are the key elements to a firm having successful organizational ethics and how do you create an effective ethics policy/program.

This program was recorded as part of ALM & Corporate Counsel's Annual General Counsel Conference on September 26th, 2019.

Provided By

General Counsel Conference


David Sobol

General Counsel & CCO
Moon Capital Management

David Sobol is the General Counsel & Chief Compliance Officer at Moon Capital, responsible for all legal, regulatory and compliance matters impacting the firm.

Moon Capital is a fundamental-research based, long/short equity manager with an emphasis on emerging markets. Mr. Sobol is a member of the firm’s Brokerage, Operations and Valuation Committees and also serves as a Director of the firm’s Singapore office, Moon Capital Singapore Pte. Ltd.

Prior to joining Moon Capital in 2011, Mr. Sobol worked in the Investment Funds Group at Akin Gump Strauss Hauer & Feld LLP in New York. Prior to that, he worked in the Investment Funds Group at Debevoise & Plimpton LLP in New York.

Mr. Sobol holds a J.D. from New York University School of Law and a B.A. magna cum laude from Georgetown University, and is admitted to practice law in New York and Missouri.

Saurabh K. Shah

Chief Compliance Officer & Regulatory Counsel

Mr. Shah serves the firm as Chief Compliance Officer and Regulatory Counsel. He joined Hines in 2017. Shah began his career at Davis Polk & Wardwell, and then worked in the Merrill Lynch Global Private Equity group and at Citigroup before spending more than four years with the U.S. Securities and Exchange Commission.

He received his BA, magna cum laude, in Biology and Political Science from Rice University. He earned his JD, cum laude, from Harvard University.

Jonathan Feiler

General Counsel and CCO (Chief Compliance Officer)
Arosa Capital Management LLP

Jonathan Feiler is the General Counsel and Chief Compliance Officer of Arosa where he is responsible for managing the firm’s legal and compliance matters.

Prior to joining Arosa, Jonathan worked in the Investment Management department at Schulte Roth & Zabel LLP from 2007 until 2015. While at Schulte Roth & Zabel LLP, Jonathan represented large institutional and entrepreneurial private investment fund managers and private investment funds (including hedge funds, private equity funds and hybrid funds) in connection with their structuring, formation and ongoing legal issues, as well as regulatory and compliance matters. Jonathan is a member of the New York State bar.

He received his J.D. cum laude from Boston University School of Law and received a B.S. in Business Administration from the State University of New York at Albany. Jonathan is a frequent speaker on legal and compliance topics at industry conferences and events.

Mimi Gross

General Counsel
Clough Capital Partners LP

Mimi Gross is the General Counsel at Clough Capital Partners L.P., where she advises the firm with regard to a wide range of issues, including structural and fund formation matters, strategic initiatives, regulatory compliance and reporting, and other operations and management issues. Clough Capital is an SEC-registered investment adviser, providing investment management to hedge funds, mutual funds and separately managed accounts.

Prior to joining Clough Capital, Mimi served as Counsel at Bingham McCutchen LLP, where her practice focused on the representation of both US and international investment advisors and funds, including hedge funds, funds of funds, private equity funds and real estate funds. Mimi holds B.C.L., LL.B. and B.A. degrees from McGill University. Mimi is a member of the Boston committee of 100 Women in Hedge Funds.

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