In this podcast I am joined by AMI Managing Director Rod Grandon. In this episode, we discuss small business compliance programs. Companies do not need to “break the bank” in order to have an effective program. The United States Sentencing Commission Guidelines Manual (Guidelines) expressly provide that the “formality and scope of actions that an organization shall take to meet the requirements of [the] guideline, including necessary features of the organization’s standards and procedures, depend on the size of the organization.” Small concerns must still demonstrate the “same degree of commitment to ethical conduct and compliance with the law as large organizations,” but may do with “less formality and fewer resources” than would be necessary of a large concern.
These programs, and their benefits, extend beyond a written set of rules and policies. Companies use ethics and compliance programs to communicate company mission statements, goals and expectations; to encourage staff to share the same set of corporate values; and to drive their behavior in day-to-day business activities.
It may be appropriate for small concerns to rely on “existing resources and simple systems.”  For example, it may be appropriate:

• For senior company leaders to discharge their responsibilities for oversight of an effective program by directly managing the company’s efforts, as opposed to hiring or designating others to do so.
• To train employees through informal staff meetings, and monitoring effectiveness through “regular ‘walk-arounds’ or continuous observation while managing the organization.”
• To use available personnel and resources, rather than employing separate staff, to run the program.
• To model the company’s ethics and compliance program on existing, high-quality programs and practices of other similar organizations (although, as noted above, there are no perfect one-size-fits-all programs – even if adopting an existing program, the company must tailor that program to the specific business needs and operational risks associated with the company’s activities).