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."
STEP 4: TRAINING AND COMMUNICATION OF STANDARDS AND PROCEDURES
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" 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 ...