Compliance plan body rests on these bones
Seven key areas form the base of plan
The Federal Sentencing Guidelines list seven essential elements that a corporate compliance program must contain. Quality managers should familiarize themselves with these elements so they can build their agency’s compliance plan around these requirements:
1. Assign a high-level person or group to oversee the plan.
2. Establish rules and procedures to reasonably reduce the prospect of illegal or wrongful acts.
3. Institute policies that prevent assignment of substantial discretion to persons that the company knew or should have known had the propensity to commit illegal acts.
4. Assure effective communication of program rules and procedures to all employees.
5. Take reasonable steps to monitor and audit operations to detect criminal conduct including establishing a system for anonymous reporting of suspected illegal conduct.
6. Use disciplinary procedures, employee annual review, and employee counseling programs to instruct employees on instances creating the duty to report suspected criminal conduct.
7. Establish appropriate responses to offenses and amend ineffective compliance plan procedures to prevent offenses when necessary.
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