On June 1st, the US Department of Justice set forth additional clarification and revised guidance for corporate compliance programs. The Covid-19 virus has changed organizations' compliance structure quite considerably.
Lack of communication! It's a phrase that's often heard in the workplace. Office-dwellers have said it, even more of us have heard it. But how does this phrase translate into the success of a whistleblower hotline or ethics reporting program?
Corporate compliance officers put quite a busy 2018 behind them at the end of the year, getting grips on some head-spinning events ranging from the #metoo movement, to getting up to speed with GDPR compliance regulations, and creating all the policies and procedures that speak to these new concerns and regulations, and how their companies need to address them.
It's not over until... well it's never over! I came across a blog post that warrants repeating - after an investigation, it ain't over! If you were to fill your car up with gas, oil, and other plethora of liquids to make it run smoothly, would you consider it 'job done'? If you plant a new tomato plant this spring, would you water it, then walk away? Cars need maintenance to run for many years, and if you really want great tomatoes, they need lots of love. The job is never done! The same applies to workplace investigators. Many may assume that once they uncover facts, prepare reports, and report their findings, their job is done. This is actually not the case. This is the perfect time to promote compliance, reinforce it's relevance in the organization, and learn from past mistakes to create a stronger work environment and culture. So here's what you should do to keep the process going and help nurture the organization:
How Strong Is Your Compliance Program? Will It Buckle Under FCPA Pressure? There's no one-size-fits-all compliance program. Depending on a variety of factors such as size, type of business, industry and risk profile, an organization should determine what is appropriate for its own needs regarding FCPA compliance program best practices. The following are 10 tips meant to provide insight into what the SEC looks for in a compliance program.
Internal whistleblowers aren't necessarily looking for a monetary reward Most employees who report wrongdoing internally do it because they believe something will be done about it. Most employees, who would potentially blow the whistle, feel that if their whistleblowing actions have a positive impact on the organization, that's incentive enough for them to report. They are not necessarily looking for a financial reward in order to report on any wrongdoing. However, a reward of some sort is a motivator for employees to take action and blow the whistle.