Chapter 10. Building a World-Class Compliance Program: The Seven Steps in Practice (Part II)

"The only thing a man can take beyond his lifetime is his ethics."

Thomas Jefferson


The FSGO require that organizations "shall take reasonable steps to communicate periodically, and in a practical manner, its standards and procedures, and other aspects of the compliance and ethics program.... and [conduct] effective training programs and otherwise disseminate information"[309] about the compliance program. Questions that organizations need to ask include:

  • Does the organization assess its risks in order to identify an appropriate training curriculum for its employees?

  • Does the company communicate to employees the consequences for compliance failures?

  • Are company values and standards communicated to vendors and other business associates?

  • Does the company have an adequate reporting mechanism for employees and others to communicate incidents and issues?

  • How does the company identify and reach all employees for training purposes?

  • Has the company determined who in the organization are considered "agents"?

  • How frequently is training provided within the organization and how often is it updated?

  • Are corporate values and issues of law properly communicated as rules that must be obeyed as drivers of the corporate culture?

  • Are members of the board provided relevant training at board meetings or in other sessions?

  • Is the compliance program budget adequate ...

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