Here are the feds' 7 tips for corporate compliance plan
April 1, 1998
Here are the feds' 7 tips for corporate compliance plan
The seven elements as listed in the Federal Sentencing Guidelines are as follows:
1. assigning a high-level person or group to oversee the plan;
2. establishing rules and procedures that will reasonably reduce the prospect of illegal or wrongful acts;
3. instituting policies that prevent assignment of substantial discretionary authority to people that the company knew or should have known had the propensity to commit illegal acts;
4. ensuring effective communication of program rules and procedures to all employees;
5. taking reasonable steps to monitor and audit operations to detect criminal conduct including establishing a system for anonymous reporting of suspected illegal conduct;
6. using disciplinary procedures, employee annual review, and employee counseling programs to instruct employees on instances creating the duty to report suspected criminal conduct;
7. establishing appropriate responses to offenses and amending ineffective compliance plan procedures to prevent offenses when necessary.