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Blogs >> Compliance Programs -- In Practice

Compliance Programs -- In Practice

In this blog, find out more about how to avoid a ‘tick box’ approach to compliance training and instead engage people in compliance training.

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Who is responsible for compliance in your organisation? The Chief Compliance Officer (CCO)? The Head of Internal Audit? The Chief Executive Officer (CEO)? The Board? Or is it something that every employee and line manager should take responsibility for?

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Stories about corporate compliance failures and the resulting eye-watering fines (or worse!) feature in the news on a regular basis. Not all incidents make the headlines: for example when someone in the organisation opens a rogue email, clicks on the attachment and downloads a malicious virus that infects the whole network, causing massive business disruption; or leaves a laptop on the train; or says nothing even if they suspect corrupt practices are going on. Sound familiar? So how can you stop this happening in your organisation?

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Several major news organizations have recently come out with articles regarding the generation, now entering the workforce, known as Millennials. This demographic group is roughly defined as those "coming of age" at the turn of the millennium. Researchers and commentators use birth years ranging from the early 1980s to the early 2000s1. The reason this group is becoming so important is that they are now the emerging workforce and their habits, social norms and cultural expectations will be shaping our economy in the next few years.

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As of April 2014, Walmart has spent $500 million on an FCPA investigation stemming from allegations that executives at Walmart’s Mexico unit bribed Mexican officials in order to expedite the opening of new stores in prime locations. Costs related to the allegations are likely to continue to increase as the investigation is ongoing and has expanded into China, Brazil and India.

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Oversight of Compliance and Ethics (C&E) programs continues to evolve, requiring C&E officers to generate, on a regular basis, meaningful reports addressing the various parts of their program. This has put pressure on C&E officers to create reports quickly and efficiently. Since there are no exact and detailed requirements for these reports, C&E professionals are left on their own to identify the correct information to present to the board and to other executives who need to have this level of visibility.

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It’s that time of year where we are all looking for a ray of light.  I recently read that Florida is the only state in the United States that has not experienced snow fall this season.  Needless to say, I don’t live in Florida!  Compliance and ethics professionals can find some good news during this endless winter in the findings of a recent study conducted by the Ethics Resource Center (“ERC”), which you can download here.  Unlike the ERC’s National Business Ethics Survey results which came out in 2011, indicating that employees were feeling more pressure to break the rules and more fearful of retaliation than in previous years, the numbers from the 2013 results seem to be following a more positive trend. 

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One of the great benefits of our Advisory Services team’s regular interactions with our clients is the opportunity to spot trends and identify the common themes that are of interest and/or concern to them.  It is always interesting to compare our observations with the topics that are creating buzz at the annual ECOA and SCCE conferences. This year’s conferences affirmed that the insights our clients have provided us are in line with the perspectives of the broader compliance community.

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It’s tempting to think of “best practices” in ethics and compliance as fixed, static, and their evolution as slow and obvious. It’s also easy to forget that our industry is only two decades old and there’s quite a lot that isn’t known about how to reduce compliance risk. At SAI Global, our Advisory Services team is tasked with continually researching and assessing emerging compliance and ethics trends and advising our clients how best to apply best practices in diverse business contexts. As a result, we often discover that generally accepted best practices are in fact in need of updating. One recent example helps refine some established ideas regarding the effective use of e-learning. E-learning has been considered the best practice for cost-effective dissemination of general compliance and ethics training for the past fifteen years and, as the technology has matured, the value of e-learning has increased as well.

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Recently, I ran into an old friend, Kim, who I hadn’t seen in many years. After catching up on life, the conversation naturally progressed to our careers. Kim shared stories about marketing for a large retail company and I told her about my work in ethics and compliance.

Kim’s response to what I do for work? Well, not quite what I was hoping for… Kim explained, “I just had to take an online course about sexual harassment. My boss rolled his eyes and told me ‘I wish I didn’t have to make you take this, but I do. Just get it over with and hopefully you won’t have to do it for another year.”

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