Survive and Thrive - What Do You Do To Survive a Code of Conduct Review By the SEC?

Thomas Fox
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One afternoon at 4 PM, you get a call from the local Securities and Exchange Commission office, and they say they want to come by in two days to review your company's Code of Conduct. You ask them why they want to review your Code. They tell you that it is a foundational document of your compliance program and view it as an internal control and, therefore, enforce it under the FCPA. They want to review all aspects of your Code design, implantation, training, and See more +
One afternoon at 4 PM, you get a call from the local Securities and Exchange Commission office, and they say they want to come by in two days to review your company's Code of Conduct. You ask them why they want to review your Code. They tell you that it is a foundational document of your compliance program and view it as an internal control and, therefore, enforce it under the FCPA. They want to review all aspects of your Code design, implantation, training, and rollout.

What steps do you need to take to demonstrate the robustness of your Code but also your training and ongoing communications on it?

How do you dig deeper and review the Code of Conduct design, implementation, and review process?

How do you make sure facts on the ground have not changed and that your Code is still relevant?

IN THIS NEW EPISODE, Compliance Evangelist Thomas Fox and Kortney Nordrum, Regulatory Counsel & Chief Compliance Officer, Deluxe Corporation, break down the steps you need to take to survive (and ace) the Code of Conduct investigation review by the SEC. 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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