The TI Six Step Approach to Implementing or Enhancing a Compliance Program


often write about what I call the McNulty Maxims of Compliance. I heard them in a presentation by Paul McNulty to the Houston Chapter of the Texas General Counsel Association in my most recent corporate position. They were (1) What did you do to prevent it?; (2) What did you do to detect it?; and (3) What did you do when you found about it? These three maxims generally translate into (1) Your compliance program, made up of policies and procedures; (2) Your internal controls to serve as both a front-line detection and back-up against corruption; and (3) What remedial steps did your company take when they discovered the issue of concern?

So how does a compliance practitioner create the compliance program, or in McNulty Maxim terms create a “What did you do to prevent it?” compliance program? Many companies are still in the infancy of creating their compliance programs with their General Counsel or perhaps hiring an initial Compliance Officer. This person or persons may be somewhat overwhelmed about how to even get started. Transparency International, in its “Business Principles for Countering Bribery: TI Guidance Document” (“Guidance Document”) has provided a specific road map for the implementation of a compliance program. Although the Chapter in the Guidance Document is designed for the Transparency International’s “Business Principles for Countering Bribery: TI Six Step Process”; this process can be used as a guide for any compliance practitioner who must create a compliance program or who needs a guide to assess whether a compliance program should be enhanced.

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