Designing a Compliance Program

Compliance is not a “one-size-fits-all” proposition. Leaders within a company should:

• Document the reasons behind the compliance training.
• Show the tools, tactics, and resources they’ve implemented to train.
• Create accountability logs to show people that have gone through the training, encouraging them to self-report what they’ve learned from the program.

If the program doesn’t work, the leader should show what adjustments he or she has made.

Federal and state regulations, as well as industry standards, evolve constantly. For this reason, leaders should conduct regular assessments to minimize the risks associated with noncompliance.

Risk factors: 

• What inherent risks exist in the company’s market?
• What efforts does the company leadership make to stay aware of the market?
• In what ways does the company solicit third-party expertise?

Objectives:

• What purpose does each module within a compliance program serve?
• In what ways do members of the team understand the objectives of a corporate compliance program?

Departmental Responsibilities: 

• In what ways does the company delegate responsibility for compliance programs?
• In what ways does the company measure excellence in delivering compliance training?
• How does the company record employee buy-in of the training?
• What do team members or stakeholders understand about reporting metrics?

Training: 

• What level of commitment does the company make to training?
• What efforts does the company make to update the training?
• In what ways can employees independently participate in computer-based training?
• How does the company measure employee engagement?

Corresponding Policies:

Like every individual has a personality, every organization has an identity. Different businesses will need a compliance program that matches the business’s identity. Some organizations may require a policy that scrutinizes new hires more than others. For example, a business that controls financial information for consumers may require criminal-background checks on all new hires, while a company that specializes in landscaping may not.

A compliance program should show a commitment to transparency. All policies should harmonize with the behavior of officials at the highest level. In this era of cloud-based computing, leaders may make use of computer-based training, encouraging members of the team to review lessons remotely. If employees have feedback, mechanisms should exist for them to provide feedback in a manner that will not undermine their position—provided they offer the feedback in a good-faith effort to promote compliance.