Under the Evaluation of Corporate Compliance Programs, Prong 2, it states:
Senior and Middle Management
Conduct at the Top – How have senior leaders, through their words and actions, encouraged or discouraged the type of misconduct in question? What concrete actions have they taken to demonstrate leadership in the company’s compliance and remediation efforts? How does the company monitor its See more +
Under the Evaluation of Corporate Compliance Programs, Prong 2, it states:
Senior and Middle Management
Conduct at the Top – How have senior leaders, through their words and actions, encouraged or discouraged the type of misconduct in question? What concrete actions have they taken to demonstrate leadership in the company’s compliance and remediation efforts? How does the company monitor its senior leadership’s behavior? How has senior leadership modelled proper behavior to subordinates?
This requirement is more than simply the ubiquitous ‘tone-at-the-top’ as it focuses on the conduct of senior management. The Justice Department wants to see a company’s senior leadership actually doing compliance. The DOJ asks if company leadership has through their words and concrete actions brought the right message of doing business ethically and in compliance to a company. How does senior management model its behavior on a company’s values and finally how is such conduct monitored in an organization? See less -
