Corporate Compliance by Carole L. Basri

Author:Carole L. Basri [Basri, Carole L.]
Language: eng
Format: azw3
ISBN: 9781632821065
Publisher: Carolina Academic Press
Published: 2017-02-28T16:00:00+00:00

Beta Testing/Communication of

New Program Phase

Prior to rolling out an updated phase of the compliance program, consideration needs to be given to the communication that should preview the assessment process. A communication issued jointly from the CEO, the compliance office, and the ethics committee and perhaps the human resources team should communicate clearly the objectives of the assessments. It would be best to first remind employees of the current state of affairs (i.e., the rollout of the program X number of years ago, the elements of the compliance program, i.e., the code of conduct/ethics booklet, the hotline material, training materials delivered, etc.). The communication should explain that the company has an obligation to update its compliance program and modify it, as may be necessary, to help the employees understand their roles in acting in accordance with the laws and regulations governing their industry. Employees should be made aware of the November 1, 2010 amendments to the sentencing guidelines and the relevancy of such to the company; i.e., increased training being provided in response to departmental “hotbeds,” etc. The communication should also explain that X percentage of the corporation's employees will be asked to complete assessments which will be a series of questions in specific business subject areas or areas in the code of conduct/ethics.

Care should be taken to assure employees that individual responses will be received anonymously although on a departmental level, certain departments will receive subject area questions that are directly relevant to that department (i.e., sales department will receive assessments concerning antitrust questions, marketing will receive questions addressing advertising practices, etc.) in addition to the more general questions areas such as, conflict of interest or travel and expense policies.

The communication should explain to employees that an initial Beta testing will be conducted pursuant to which a few employees from each department will be requested to “preview” the assessments and provide feedback so that further refinements and adjustments for clarity and understanding could be done prior to the rollout of the online assessment survey to the larger employee population. To receive honest feedback and gain the employees willing cooperation, it is important to explain that the assessments will not be used to identify violators or terminate employees, but rather for issue spotting so that the company can determine if its compliance program elements require modification and are serving the employees needs for guidance and direction in the areas that affect their day to day business activities.

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