31 Days to a More Effective Compliance Program - Day 22 | Internal reporting and triaging claims

Thomas Fox
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The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the process which will determine, in many instances, how the company will respond going forward.

Internal reporting. The 2020 FCPA Resource Guide has as clear and concise a statement about hotlines as any other requirement See more +

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the process which will determine, in many instances, how the company will respond going forward.

Internal reporting. The 2020 FCPA Resource Guide has as clear and concise a statement about hotlines as any other requirement found in Hallmarks of an Effective Compliance Program. It states: "An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation."

Triaging claims. Given the number of ways that information about violations or potential violations can be communicated to the government regulators, having a robust triage system is an important way that a company can determine what resources to bring to bear on a compliance problem.

Three key takeaways:

1. The DOJ and SEC put special emphasis on internal reporting lines.

2. Test your hotline on a regular basis to make sure it is working.

3. Have an investigation protocol in place before the call comes in so you will be ready to go and not required to scramble to create a protocol. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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