1. Establish and maintain an effective Compliance Management Program.
The first step in establishing a compliance management program is to develop a policy and procedures manual. This document will outline the organization’s compliance requirements and how employees are expected to comply with them. The compliance management program should also include:
-A system for assessing the organization’s compliance risk
-Policies and procedures to mitigate compliance risk
-Training for employees on their responsibilities under the compliance management program
-Regular reviews of the compliance management program to ensure it is effective
-A system of internal controls
-Reporting of violations of law or company policy
-Cooperation with investigations into potential wrongdoing
-Corrective action to address findings from a compliance audit
2. Assess the organization’s compliance risk.
In order to assess the organization’s compliance risk, it is necessary to identify which regulations apply to the company and how they impact its business. The organization should then develop a risk matrix that assigns a risk rating to each regulation based on how likely it is that the company will violate it. This assessment will help to determine which areas of the business are most at risk for noncompliance.
3. Implement policies and procedures to mitigate compliance risk.
Once the organization has determined its areas of highest compliance risk, it must develop policies and procedures to mitigate those risks. These may include specific steps employees must take to ensure compliance with a regulation, or restrictions on certain activities that could lead to noncompliance.
4. Train employees on their responsibilities under the Compliance Management Program.
It is essential that all employees be trained on their responsibilities under the Compliance Management Program. This training should cover not only what is required by the program, but also how to identify potential violations and report them.
5. Conduct periodic reviews of the Compliance Management Program.
The effectiveness of the Compliance Management Program should be periodically evaluated by conducting reviews of its policies and procedures, as well as its implementation and results. These reviews should identify any areas that need improvement and suggest corrective actions.
6. Develop and implement a system of internal controls.
A system of internal controls is important for ensuring that employees adhere to company policy and avoid non-compliance. The system should include specific procedures for implementing policies, monitoring employee behavior, and reporting any violations.
7. Report violations of law or company policy.
Employees must be made aware that they are responsible for reporting any violations of law or company policy. They should also be told how to report these violations, and who to report them to.
8. Cooperate with investigations into potential wrongdoing.
If an investigation is launched into potential wrongdoing, all employees must cooperate with the investigation. This includes providing any relevant information and documents and testifying truthfully if called upon to do so.
9. Take corrective action to address findings from a compliance audit.
If a compliance audit finds that the company has violated a regulation, it is important to take corrective action to ensure that the violation does not happen again. This may include changing policies and procedures, increasing employee training, or taking disciplinary action against employees who were involved in the violation.
10. Maintain accurate records of compliance-related activities.
It is important to maintain accurate records of all compliance-related activities, including employee training, policy changes, and investigations. These records can be used to show that the company is taking its compliance obligations seriously and taking steps to ensure that its employees are in compliance with the law.