Good morning, and welcome back. This is the eighth edition of OIG Shorts, a publication of Sheppard Mullin’s Organizational Integrity Group. In this series, we discuss practical approaches to creating a more effective Ethics & Compliance program. Past editions have provided tips on ensuring the Ethics and Compliance program is reality‐based, not letting the program become a check‐the‐box exercise, and measuring the program’s efficacy.

Today, we discuss a compliance obligation that is sometimes honored in the breach: regular compliance self‐assessments...