Assessing Codes of Conduct

Assessing Codes of Conduct

Codes of conduct are often described as the most important document in a compliance program. Codes help set the right tone for compliance and ethics (“C&E”) programs.  They are educational tools that should serve to raise awareness and understanding of important...
Program Structure

Program Structure

In the posts collected here we will discuss assessment-related issues concerning a) various types of C&E program roles and reporting relationships, including those involving the board of directors; senior management; C&E department management; other staff,...
Revisions to DOJ Program

Revisions to DOJ Program

On June 1, 2020, the U.S. Department of Justice (“DOJ”), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs” (“the  2020 Update”) to provide increased clarity on several of the key questions prosecutors might ask in assessing...