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Jeff Kaplan, Aug 04, 2010
As noted in the first of this series on C&E program assessments, in addition to reviewing program elements (such as training and auditing) an assessment should address key program “attributes” - important characteristics of programs that cut across multiple program elements. They are: program authority, reach, resources and independence; management’s knowledge and support of the program; ethics, as well as compliance; and organizational culture.
The list is based not only on government C&E program expectations and good practices but also on what might considered the known history of program failures. In this and subsequent postings I will provide an overview of these attributes.
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Alice Peterson, Jul 26, 2010
Should we worry that the financial incentive provision embedded in the Dodd-Frank Wall Street Reform and Consumer Protection Act will be problematic for compliance and ethics programs? I think so.
Hailed as a sweeping overhaul of U.S. financial market regulations, the Dodd-Frank Act was a response to the global financial crisis which came to a head in 2008. Although this new law is an important step forward in improving U.S. financial regulation, it represents a challenge to C & E programs in one important regard.
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Jeff Kaplan, Jun 21, 2010
Under one of pending revisions to the Corporate Sentencing Guidelines, i) the employee with operational responsibility for a company’s C&E program should directly report to the board of directors (or committee thereof) ; and ii) such “direct reporting obligations” should entail the individual having “express authority to communicate personally to the [board] (A) promptly on any matter involving criminal conduct or potential criminal conduct, and (B) no less than annually on the implementation and effectiveness of the C&E program.” The mention of “express authority” presumably means that the authority in question should be documented. But what kind of documentation works best for these and other C&E program purposes?
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