An effective corporate compliance program is an essential component of internal controls for uncovering and preventing ethical lapses and criminal violations and smart companies are prudently adopting these programs. However, it is not enough to merely implement the program. It is also essential the program is properly and competently administered and maintained. This article acknowledges broadly accepted fundamentals of any corporate compliance program, explores common mistakes made during implementation and maintenance of the programs, and concludes with recommendations based upon Department of Justice and Securities and Exchange Commission guidance.
WHAT ARE THE FUNDAMENTALS OF ANY CORPORATE COMPLIANCE PROGRAM? -
The purpose of a corporate compliance program is to promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.2 Consensus suggests an effective corporate compliance program will incorporate the following essential elements...
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