by kwalker | Aug 19, 2020 | Uncategorized
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...
by kwalker | Aug 19, 2020 | Uncategorized
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,...
by kwalker | Jun 13, 2020 | Uncategorized
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...
by kwalker | Dec 10, 2018 | Uncategorized
Legal guidance in the area of C&E program assessments accords with professional wisdom in this area, emphasizing the importance of periodic assessments to an effective program. In this post, we review a few of the relevant legal standards from U.S. authorities....
by kwalker | Sep 19, 2018 | Uncategorized
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...
by kwalker | Jun 25, 2018 | Auditing, monitoring, and other "checking", Uncategorized
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...
