Section 4

Amplifying Your Impact

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Set and Beat Your Benchmarks

See how your compliance program stacks up against your peers and learn new strategies to increase the effectiveness of what you’re already doing. 

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Achieving an effective ethics and compliance program requires more than simply adding rules and additional layers of controls. There must be an integrated effort that aligns financial and compliance requirements with the organization’s mission and values. The steps you take as a compliance professional should not be in isolation of your organization’s larger business objectives but in support of them.

Along with aligning with organizational goals, your compliance program can compound its impact by focusing on industry best practices that maximize efforts. This section will highlight the latest best practices in the use of technology, program automation and industry benchmarks to amplify the impact of key compliance program elements.

Shifting Perspectives on COI in the Modern Workforce

Conflict of interest (COI) practices have generally remained consistent over time, but legal and regulatory changes as well as technological and societal changes have made this an ideal time for organizations to reconsider how they handle conflicts of interest.

Jeff Kaplan, Rebecca Walker; Partners Kaplan & Walker LLP

Conflict of interest (COI) practices have generally remained consistent over time, but legal and regulatory changes as well as technological and societal changes have made this an ideal time for organizations to reconsider how they handle conflicts of interest.

As environments will inevitably continue to shift, companies should assess their conflict of interest programs in light of best practices. Review these 5 best practices to keep pace with the evolving COI landscape:

  1. Implement COI certifications for higher-risk employees. Using a risk-based approach, identify employees who carry a high-level of COI-related risk. Administer COI certifications to those specific employees at an appropriate frequency.
     
  2. Conduct a COI risk assessment. Review common risk areas such as economic relationships with customers, competitors and suppliers, and family employment issues. Determine which risk areas require additional mitigation. Seek to identify uncommon risk areas, too.
     
  3. Review and update your COI policy. Make sure your policy addresses actual, apparent and potential COI risks. Develop clear processes for handling COI-related questions and disclosures - so that when they arise you have a procedure to follow. Ensure that your COI policy conforms to applicable law.
     
  4. Train employees on you COI policy. Train employees regularly using appropriate, job-specific content. Again, follow a risk-based approach to identify employees with significant risks and provide them with role-specific training.
     
  5. Automate your voluntary disclosure process. Use an automated process to administer policies, capture attestations, and handle voluntary disclosures. After an employee reviews your COI policy, require them to voluntarily disclose any potential conflicts of interest they may have. This will reduce your risk, while providing your employees with an opportunity to become part of your COI efforts.