Regular Analysis

With changes in the regulatory landscape, an enterprise must show a concerted effort to stay on top of changes in laws and regulations and a pattern of continuously analyzing the effectiveness of its compliance or training program. Leaders should record every change, showing the company’s commitment to excellence. By documenting best practices, the company goes a long way toward building credibility with investigators.

Some useful tools to demonstrate a willingness to analyze and improve may include:

• Confidential performance reviews from immediate superiors,
• Confidential performance reviews from subordinates,
• Randomized peer reviews,
• Quarterly reviews by senior management,
• Periodic company-wide town halls to discuss the general direction of the company and important corporate developments,
• Management accessibility via internal email, and
• Documented strategies for internal corporate communications. 

An effective compliance program will show a company’s commitment to do the right thing all the time, leading to more confidence that the enterprise can withstand an inquiry by investigators. Regulators look favorably upon such programs. By enacting steps to analyze and improve compliance policies, leaders show that they are not running the company with a seat-of-their-pants approach, nor are they engaged in willful blindness that could lead to charges of criminal negligence.