When it comes to translations, there’s more to consider than meets the eye. It’s important to think about translating your Code of Conduct, even if you are a purely domestic organization. The key is to look closely at your employee population and your stakeholder population to determine what languages are necessary. Lastly don’t forget to take a close look at your English version. If your English is too complicated, then your translations will be too complicated.
The US Sentencing Guidelines require that individuals within an organization be delegated with day-to-day operational responsibility for the compliance program. When defining the role of this individual, the Guidelines say that the person with day-to-day operational authority shall report to high level personnel, and when appropriate, the governing authority of the organization on the effectiveness of the…
The U.S. Sentencing Commission’s data can tell us some very interesting and helpful things about the size of organizations that get in trouble, the types of offenses or actually the multiplicity of offenses that organizations find themselves charged with probably most importantly can talk very specifically about the collateral damage if you will that comes with a federal prosecution in the form of individuals that get prosecuted. These are all helpful pieces of information and you’re making the case internally for the necessity of compliance.
Keep your training effective, periodic and practical. Periodic doesn’t mean once and it’s done, it means periodic. Practical means testing to ensure that the program is working. And finally, use consistent and interesting training to ensure effectiveness.
While anti-corruption is a very serious risk it is one with very low likelihood for many organizations. Every organization needs to understand their own particular risks. By doing that you will know if you need to have an anti-corruption program.
If you’re going to market your program’s success either internally or externally be prepared for some scrutiny, be prepared to support that the organization meets “best practices” and most importantly be prepared to continue on the long hard slog to keep the program up to snuff.
This is part of a continuing series called Sentencing Commission Confidential. Let’s take a look at the history and operation of the sentencing guidelines and in particular chapter 8 of the sentencing guidelines that have to do with organizations. Let’s go back in time to 1984, this was before the United States Sentencing Commission.…
If you want to avoid having a whistleblower you need to focus on your culture. Invest in middle management and understand the perception of retaliation in your organization these three things overlap and there are vitally important to keeping people reporting inside your organization.
The Code of Conduct is the Foundation Why does the Department of Justice and the SEC call the Code of Conduct the foundation of an effective compliance and ethics program? This question is something that has come up often over the last few years and this terminology— the foundation has become a buzzword. Let’s take a…
The SCCE Compliance and Ethics Institute Conference in Chicago on September 24-27, 2016 is the stage for this podcast. Eric Morehead, host of Compliance Beat was in attendance, along with 1700 compliance professionals and shares conference highlights and emerging trends in this Special Edition.