31 Days to a More Effective Compliance Program - Operationalization of your Code of Conduct

Thomas Fox
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How can you work to operationalize your Code of Conduct as articulated in the DOJ 2019 Guidance? The 2019 Guidance focuses not on whether a company has a paper compliance program but whether a company is actually doing compliance. A company does compliance by moving it into the functional business units as a part of an overall business process. That is what makes a compliance program effective at the business level. There are several different parts of the 2019 Guidance that touch upon your Code of See more +
How can you work to operationalize your Code of Conduct as articulated in the DOJ 2019 Guidance? The 2019 Guidance focuses not on whether a company has a paper compliance program but whether a company is actually doing compliance. A company does compliance by moving it into the functional business units as a part of an overall business process. That is what makes a compliance program effective at the business level. There are several different parts of the 2019 Guidance that touch upon your Code of Conduct.

All of these requirements point to getting out and making your Code of Conduct a part of the very fabric of your organization. By using some or all of these strategies, you will have a good starting point. But it is more than simply rollout and training. There must be ongoing communications as well.

Three key takeaways:

1. What has been the role of senior management in the creation or update of your Code of Conduct?

2. How have you worked with employees outside the compliance function to lay the groundwork for fully operationalizing your Code of Conduct?

3. How have you measured the effectiveness of your Code of Conduct training? 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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