Simply having a Code of Conduct, together with compliance policies and procedures is not enough. As articulated by former Assistant Attorney General Lanny Breuer, “Your compliance program is a living entity; it should be constantly evolving.” The 2012 FCPA Guidance stated “When assessing a compliance program, DOJ and SEC will review whether the company Guiding Principles of Enforcement has taken steps to make certain that the code of conduct remains current and effective and whether a company has periodically reviewed and updated its See more +
Simply having a Code of Conduct, together with compliance policies and procedures is not enough. As articulated by former Assistant Attorney General Lanny Breuer, “Your compliance program is a living entity; it should be constantly evolving.” The 2012 FCPA Guidance stated “When assessing a compliance program, DOJ and SEC will review whether the company Guiding Principles of Enforcement has taken steps to make certain that the code of conduct remains current and effective and whether a company has periodically reviewed and updated its code.” See less -