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 intended to be asked in addition to, and not in lieu of, questions about actual violations of law and policy.
C&E knowledge questions might include some of the following – tailored, as appropriate, to the interviewee’s job duties:
• Are you aware of company policy regarding
o Offering and receiving gifts and entertainment?
o Providing travel and other things of value to customers and government officials?
o Engaging third parties to represent the company in dealing with governmental entities?
o Making facilitating payments?
o Having contact with competitors?
o Addressing conflicts of interest?
o Taking annual C&E training?
o Reporting possible misconduct?
Yes answers to any of these of these should trigger follow-up questions designed to test the knowledge the interviewee says she has. Some examples:
• What would you do if a customer asked you to refer his or her family member for a job at the company?
• What are the approval requirements before providing a meal to a government employee?
• What topics are forbidden to discuss with competitors?
• What should be done if you have a possible conflict of interest?
• What are the channels for reporting suspected wrongdoing?
• How would you seek advice on an ethical matter?
• Where can you find copies of company C&E policies?
As noted, questions should be tailored to the interviewee’s duties. For instance, managers (but not necessarily other employees) should generally be asked if they would know what to do – and what not do – if an employee reported suspected wrongdoing to them. Or, selected interviewees might be asked if they would know what to do and not do in the event of a “Dawn Raid.”
The benefit of using C&E knowledge questions in audits is not only in the value of what is learned from the answers. The mere asking of such questions can send a message that may travel widely in a company about the importance of C&E generally to management. Of course, deploying such questions also incurs a cost in terms of the time and resources of audit staff and other employees, and the use of such questions can decrease the time available for taking other important audit measures. However, such questions can be a valuable tool in the audit/assessment tool box, and companies should thus consider the costs and benefits of such a practice.
