Compliance Program: Seven Elements
of an Effective Compliance Program
Questions and Answers.
Seven Elements of an Effective Compliance Program - Answer (1) Standards, Policies, and
Procedures
(2) Compliance Program Administration
(3) Communication, Education, and Training
(4) Monitoring and Auditing
(5) Internal Reporting Systems
(6) Discipline for Noncompliance
(7) Investigation and Remediation Measures
Effective Compliance and Ethics Program Components (Not All-Inclusive) - Answer (1) Code of
conduct and relevant compliance policies and procedures
(2) Oversight and accountability by the board for the compliance program
(3) Education, communication, and awareness
(4) Delegation of authority
(5) Enforcement, discipline, and incentives
(6) Monitoring and auditing
(7) Internal investigations, including a root cause analysis and corrective action plans
(8) Consistent and fair discipline
(9) Risk assessments
(10) Effective assessments of the compliance and ethics program
(11) Ongoing program improvements.
Element 1: Standards, Policies, and Procedures (Code of Conduct) - Answer An organization
should have an established set of compliance standards and procedures. These standards
should not be a "paper only" document, but a living document that promotes organizational
culture that encourages ethical conduct and a commitment to compliance with applicable
regulations and laws.
"Standards and Procedures" (Compliance) - Answer Means standards of conduct and internal
controls that are reasonably capable of reducing the likelihood of criminal conduct.
Code of Conduct - Answer a statement that guides the ethical behavior of a company and its
employees
, Code of Conduct - Content Checklist - Answer - demonstrates system wide emphasis on
compliance with all applicable laws and regulations.
- written plainly and concisely so all employees can understand the standards
- translated into other languages
-includes internal and external regulations
- mentions org policies w/out completely restating.
- consistent i/ org policies and procedures.
- includes management's responsibility to explain and enforce the code
Code of Conduct - Communicating to Employees Checklist - Answer - all employees must
receive, read and understand that standards.
- a supervisor should explain the standards and answer any questions.
- employees should attest in writing that they have received, read and understand the
standards.
- employee compliance w/ the standards must be enforced through appropriate discipline when
necessary.
- discipline for noncompliance should be stated in the standards.
Code of Conduct - Purpose Checklist - Answer • To present specific guidelines for employees
to follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
Policies and Procedures - Answer Specific and address identified areas of risk. The only thing
worse than not having a policy is having one and not following it.
Structural Policies (Compliance and Ethics) - Answer Create the framework for how the
compliance and ethics program will operate
Substantive Policies (Compliance and Ethics) - Answer Define the applicable regulations that
apply to the organization and how to operate compliantly within those regulations.
Structural Policies and Procedures Should Address: - Answer -Directives or mission of the
compliance and ethics program
of an Effective Compliance Program
Questions and Answers.
Seven Elements of an Effective Compliance Program - Answer (1) Standards, Policies, and
Procedures
(2) Compliance Program Administration
(3) Communication, Education, and Training
(4) Monitoring and Auditing
(5) Internal Reporting Systems
(6) Discipline for Noncompliance
(7) Investigation and Remediation Measures
Effective Compliance and Ethics Program Components (Not All-Inclusive) - Answer (1) Code of
conduct and relevant compliance policies and procedures
(2) Oversight and accountability by the board for the compliance program
(3) Education, communication, and awareness
(4) Delegation of authority
(5) Enforcement, discipline, and incentives
(6) Monitoring and auditing
(7) Internal investigations, including a root cause analysis and corrective action plans
(8) Consistent and fair discipline
(9) Risk assessments
(10) Effective assessments of the compliance and ethics program
(11) Ongoing program improvements.
Element 1: Standards, Policies, and Procedures (Code of Conduct) - Answer An organization
should have an established set of compliance standards and procedures. These standards
should not be a "paper only" document, but a living document that promotes organizational
culture that encourages ethical conduct and a commitment to compliance with applicable
regulations and laws.
"Standards and Procedures" (Compliance) - Answer Means standards of conduct and internal
controls that are reasonably capable of reducing the likelihood of criminal conduct.
Code of Conduct - Answer a statement that guides the ethical behavior of a company and its
employees
, Code of Conduct - Content Checklist - Answer - demonstrates system wide emphasis on
compliance with all applicable laws and regulations.
- written plainly and concisely so all employees can understand the standards
- translated into other languages
-includes internal and external regulations
- mentions org policies w/out completely restating.
- consistent i/ org policies and procedures.
- includes management's responsibility to explain and enforce the code
Code of Conduct - Communicating to Employees Checklist - Answer - all employees must
receive, read and understand that standards.
- a supervisor should explain the standards and answer any questions.
- employees should attest in writing that they have received, read and understand the
standards.
- employee compliance w/ the standards must be enforced through appropriate discipline when
necessary.
- discipline for noncompliance should be stated in the standards.
Code of Conduct - Purpose Checklist - Answer • To present specific guidelines for employees
to follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
Policies and Procedures - Answer Specific and address identified areas of risk. The only thing
worse than not having a policy is having one and not following it.
Structural Policies (Compliance and Ethics) - Answer Create the framework for how the
compliance and ethics program will operate
Substantive Policies (Compliance and Ethics) - Answer Define the applicable regulations that
apply to the organization and how to operate compliantly within those regulations.
Structural Policies and Procedures Should Address: - Answer -Directives or mission of the
compliance and ethics program
