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 […]
Effective Lines of Communication with the Compliance Officer and Disclosure Program: Element 6
The age-old question of “if a tree falls in the forest and no one is there, does it make a sound?” may not seem applicable to compliance but I assure you it is. If staff report a compliance issue and no one hears them, why even take the time to make the report? One of […]
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 […]