Compliance Stuff

Compliance and ethics program assessments sometimes have a general scope and are sometimes focused on a single substantive risk area—such as corruption or competition law. For some companies, it makes sense to do such a targeted/deep dive assessment for conflicts of interest (COIs). This is particularly so for those responding to a significant COI violation or “near miss,” but it is also the case where the likelihood of COI risks is heightened due to geographic, organizational, or industry cultural considerations. The scope and approach of such assessments for any given company at any given time should vary based on various circumstances. Though, as a general matter, what does one look for in a COI program assessment? Risk assessment : Has the company assessed COI risk? If so, has it been done in a documented way? Has it used the assessment(s) results in designing and implementing other aspects of the COI program? Governance : Have the respective COI oversight roles of the board of di...

  Employee surveys have long been part of the compliance and ethics (C&E) landscape.  This post is offered as a brief introduction to practices and views relating to such surveys. Why survey Employee surveys can provide a broad array of information about many key C&E issues at a company.   Most prominently they can assist companies in understanding and addressing challenges relating to C&E culture . This can help in various aspects of program self-assessments – and thus be useful to boards and top managers, among others.   They can also help in program design and implementation in many other ways.  Among other things, survey data can play a significant role in a risk assessment. Note, too, that surveys can be used to obtain C&E information on a granular basis.  For large global companies this can be invaluable. In addition, the Department of Justice increasingly expects companies to provide data in enforcement matters . They have pushed us t...