Getting your managers involved in your compliance program is a best practice and also the most effective way to address compliance culture locally. In this episode Eric talks about three key criteria to consider when putting together a plan for involving managers: training, resources and measurement. Eric discusses some practical ways to implement such a plan.
As more and more compliance professionals join the ranks from other disciplines, it’s important that we reinforce the role of the US Sentencing Commission, and maybe even more importantly, the public’s role in defining the compliance and ethics standards all of our programs are based on.
Listen to a short description of what the Sentencing Commission is, and their role in our profession — both past and future.
Also, join Eric for a webinar next week on Thursday, November 7th at 1PM ET: Updating Your Code of Conduct: Best Practices.
There’s not a lot of data out there to tell us how the Department of Justice or other regulators view compliance initiatives, or what expectations really are. We know what the guidance tells us, but what happens in the real world when a company’s compliance program is looked at? We can get some indications from Sentencing Commission data that tells us what happens to those unlucky companies that face a Federal judge for sentencing.
For this episode Eric dives into the commonly conflated terms “substantial authority personnel” and “high-level personnel” that are defined in the Sentencing Guideline standards for an effective compliance and ethics program. Knowing which is which, and what the expectations are for a compliance program, is very important and not often discussed.
Eric spends a few minutes looking back at CEI’s past — and talking about the threads and new trends in this year’s event. If you are visiting DC this week then come by and see Eric at Booth 106. If not, we hope to see you next time!
“SCCE’s annual Compliance & Ethics Institute is the primary educational and networking event for compliance professionals across all industries around the world. Each year we host more than 1,600 attendees from 40 countries.”