Responding to Detected Offenses and Developing Corrective Action Initiatives: Element 7

One of the most important aspects of an effective compliance program is making corrections to the systems or processes of the organization when something does go bump in the night. The Department of Justice, in its March 2023 Evaluation of Corporate Compliance Programs document specifically addresses this essential element. As stated by the DOJ “One […]

Enforcement of Discipline: Element 5

Written by: Sam Jones When you encounter someone’s dog, you can learn a lot about them. One aspect that becomes immediately evident is how effectively they enforce discipline. We’ve all witnessed those impressive dogs that obediently follow every command from their owner. These dogs sit and wait patiently until they are released; upon hearing words […]

Internal Monitoring and Auditing: Element 4

Written by: Sam Jones One of the ways you can see if your program is effective or not is by taking a pulse of the impact it has throughout your organization. This is why having systems and processes in place for auditing is essential. Your organization may already have some aspects of this in place […]

Training and Education: Element 3

Written by: Sam Jones Having a Compliance Officer and a manual with policies and procedures is important, but it only goes so far. The only way a compliance program is put into action is through regular training and education throughout the organization. So, what are the expectations when it comes to training and education for […]

Dedicated Compliance Officer and Compliance Committee: Element 2

Written by: Sam Jones Last month, we kicked off this new series, walking through the 7 elements of a compliance program, starting with Standards, Policies, and Procedures. This element serves as the foundation and beginning of your compliance program, but you can’t stop there. Having a binder on the shelf or a document on the […]

Effective Elements of a Compliance Program: Element 1

Written by: Sam Jones From time to time, it is important to revisit the fundamentals of your compliance program. If you’ve already gone through the 7 elements of the compliance program and implemented them, congratulations! You’re on the right track and taking proactive steps for compliance effectiveness. If you’re just starting this process, this is […]

Culture – Written in Sand Rather Than Set in Stone

We hear a lot about culture these days.  It seems every business management guru says the culture of the organization is the foundation for everything that happens.  I tend to agree with that statement; without a solid culture, the organization can often function more like a ship without a rudder, or a child chasing the […]

Compliance New Year’s Resolutions

As we turn the page on what can only be described as a “one of a kind” year we have a tremendous opportunity to look back at 2020 and really evaluate how the compliance program performed, and where 2021 might provide some opportunities to improve, change direction or re-tool the program. The pandemic forced providers […]

Dynamic and Evolving

In June 2019, when the Criminal Division of the Department of Justice, (DOJ), updated its guidance document on how prosecutors are to evaluate an organization’s compliance program, (Evaluation of Corporate Compliance Programs), one theme comes through loud and clear.  Compliance policies, procedures and controls should never become stale or stagnant.  Rather, the DOJ takes the […]

The Sequence is Important

Compliance program, policies, procedures, Code of Conduct

As I write this blog post I am watching the crew working on the road in front of my office. It has been a long 5 months, yes COVID has impacted us, but we have also been unable to get into our office parking lot due to a complete reconstruction of First Street where our […]

Dust Off the Code of Conduct and Bring It Back to Life

Most every compliance program has a document called the Code of Conduct, Code of Ethics or some other title that indicates the organization’s “commitment” to doing the right thing. Typically the document was drafted when the compliance program was first developed, and likely has not received much attention since then. It may be printed in […]