Corpedia, a consulting and e-learning provider of compliance and ethics solutions and training, recently released its recommendations on what compliance measures companies can take to weather the storm, as reported in a recent article in Supply and Demand Chain Executive.
Since the Justice Department is already investigating 120 companies for violations of the FPCA (Foreign Corrupt Practices Act), up from 100 last year, and the year is only half over, you should make sure you are heeding these points. The government needs money too … and if they think they can fine you millions, or billions, of dollars … now is the time they’re going to be banging on your door.
The five measures, which are very common-sense and easy to implement, are the following:
- don’t wait until it’s too late
even if you don’t have the budget for everything you’d like to do, you can start designing your program now and identify process improvements to improve your state of operations and implement your program incrementally (and if you happen to be unknowingly violating an act, the government will be a lot more lenient if they see you were taking measures to prevent accidental violations) - articulate expectations
unless you effectively communicate a clear, comprehensive code of conduct, and reinforce desired behavior from time to time, you can’t expect that your employees will always know what to do - you can’t run or hide … so don’t try
you must be organized, transparent, and accountable … because even if you have nothing to hide, you’ll look like you do … and that alone could trigger a costly investigation - work out the old, bring in the new
review and modify existing policies and procedures as necessary and create new controls to insure they are followed - utilize available knowledge
Take advantage of available research that sheds light on others’ successes and failures and outlines the framework for a bulletproof compliance program