Author: Kaplan Walker

PLI One-Hour Briefing on Compliance & Ethics Program Assessment

On September 28 at 1:00 Eastern Rebecca and Jeff will be leading a One-Hour Briefing for the Practising Law Institute on C&E program assessment. The program will cover: Official requirements for conducting C&E program assessments and business-related reasons to do

Assessing compliance incentives

There are two types of incentives that typically should be reviewed in a C&E program assessment. The first concerns the extent to which a company’s general incentive structure has the effect (presumably unintentional) of promoting non-compliance. The second concerns incentive

Assessing the E&C Investigations Process

Investigations are one of the more difficult and riskier activities of an E&C program. Poorly-conducted investigations can create serious legal risks for an organization. In addition, the mishandling of investigations can damage the way in which employees perceive E&C programs,

Assessing compliance training

Training is not just another part of every C&E program; it is generally the part that touches the work lives of more of a company’s employees than do other elements. It should therefore be a significant focus of any program

Audit Interviews Regarding Employee C&E Knowledge

An often useful but not always used self-assessment tool is to include in an audit interview questions to determine if employees have sufficient knowledge of C&E program requirements and resources. Knowledge questions – as these might be called – are

Assessing risk assessment

When the Federal Sentencing Guidelines for Organizations were first issued in 1991, risk assessment was not among the specified elements of an effective C&E program. By the time risk assessment was added to the definition of an effective C&E program