Implement What You Know with Confidence
Discover action-based tools that provide simple steps for program improvement or robust plans for new ways of doing business.
Your ethics and compliance program is an ecosystem of moving parts. New laws and regulations, new lines of business, new geographies, mergers and acquisitions become part of a growing enterprise that your compliance ecosystem must support.
Effective compliance programs are able to deftly navigate these complexities because they have built strong foundations that were developed with the nature of the compliance industry in mind.
This section will give you the expert advice and programmatic best practices to ensure the first steps you take to develop your program are in the right direction. Or if your program is more mature, these resources and insights will give you the necessary guidance to course correct and improve your program’s foundation at whichever stage it is in.
Chapter 8 of The Worst-Case Scenario Survival Guide for Compliance Professionals
For the first time, companies that sustain an FCPA violation are required to perform a root-cause analysis and incorporate that information back into the compliance program. Learn how to survive with Tom Fox.
Chapter 8 of The Worst-Case Scenario Survival Guide for Compliance Professionals
For the first time, companies that sustain an FCPA violation are required to perform a root-cause analysis and incorporate that information back into the compliance program. Learn how to survive with Tom Fox.
4. Improve Controls, Don’t Just Blame People
Don’t jump to blaming people for bad systems and processes - unless you uncover willful negligence or gross incompetence. Toughen up, admit that it might be your program, remediate it and move forward. Your employees are doing the actual thinking and processing to generate profits for your company. You do not have to stop their activities nor do you have to penalize with discipline. That is part of the reason a root-cause analysis can be such a powerful tool. It identifies what led to the failure without any guesswork.
5. Use the Findings
After you have identified the root-cause of a problem, it’s key to consider the solutions that can be implemented by logically using data that already exists in the organization. Identify current and future needs for organizational improvement. Your solution should be a repeatable, step-by-step process in which one process can confirm the results of another. Focusing on the corrective measures of root causes is more effective than simply treating the symptoms. You will have a much more robust solution in place. This is because these types of solutions are accomplished through a systematic process with conclusions backed up by evidence.
Under the Evaluation, Prong 1, it stated: Remediation – What specific changes has the company made to reduce the risk that the same or similar issues will not occur in the future? What specific remediation has addressed the issues identified in the root-cause and missed opportunity analysis?
The Justice Department clearly expects you to not only perform a root-cause analysis for every compliance failure but, more importantly, to also use that information going forward. By following these steps you will survive the root-cause analysis requirement of the Evaluation and thrive as an organization.
Illustration by Dex Novak
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