One of the key changes coming out of the Covid-19 pandemic is the need for dynamism on corporate policies. This message was driven home in
More than simply having a Code of Conduct, compliance policies and procedures are required. As former Assistant Attorney General Lanny Breuer articulated, “Your compliance program
There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the
How can you work to operationalize your Code of Conduct as articulated in the DOJ 2023 Evaluation of Corporate Compliance Programs (ECCP)? The 2023 ECCP
What about the training on your finalized Code of Conduct? While there have been criticisms of code training, if you consider training as one source
Next comes the evolution of the structure and format of a best practices Code of Conduct. Initially, my experience with this is that they were
What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to
The written standard requirements have long been memorialized in the U.S. Sentencing Guidelines, which contain seven basic compliance elements that can be tailored to fit
The cornerstone of any best practices compliance program is written protocols. This includes a Code of Conduct, policies and procedures. These elements have long been
As we end this month on the intersection of HR and compliance, I have developed a series of goals and objectives which you might want
