1. Board of directors assuming compliance responsibility
The board needs to make it clear within the corporation and to shareholders that it is the body with the authority for compliance success and failure.
2. Commiting to compliance
Active support needs to trickle down from the board through each ascending layer of the enterprise, actively supporting the effort with extra resources, staff and meetings along the way.
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3. Management communicating its importance
Acting on that commitment assertively is key. This can be done with clear, ongoing goals that exceed legal minimums for the entire organization and programs that can withstand a challenge by proactive class action attorneys.
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4. Management putting in place consequences for those who do not comply
Senior management needs to outline meaningful sanctions (i.e. loss of compensation, demotion, suspension or termination) for any employee who does not adhere to the standards.
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5. Looking beyond compliance
Remember that you're establishing compliance as a tool for long-term strategic and operational improvements. The end-game isn't compliance, it's what efficient compliance can enable.
6. Making the compliance message as clear and simple as possible
Make sure that message covers legal, regulatory and ethical obligations and is easy to grasp for employees throughout the enterprise. There should also be well-defined leaders for each category of compliance.
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7. Communicating the compliance program and objectives to everyone
Make a set of standards known to everyone as a basis for compliance rules and, given those rules, provide examples of poor conduct.
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8. Providing detailed policies, procedures and backup with training
Managers and employees need to have quick access to detailed instruction. If employees dont know what is expected of them or where to turn for help, compliance violation will most likely follow.
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9. Integrating compliance with business operations
Companies with successful compliance programs integrate those programs into the business processes and incentive structures of the company to correct violations as they occurfor example, development activities. Rather than reaching the end of a development process and having a quick compliance review, embed compliance design within the process so that potential issues are identified and resolved early with limited expense.
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10. Preparing for a breach in compliance with processes in place to adress the violations
Meeting compliance standards is only the start. Ongoing staff and procedures need to be in place to continually know compliance risk inside-and-out and mitigate potential violations.