Sunday, June 23 | 1:00-5:00 PM
CPE Credit: 4.2
Level: Intermediate
Recommended Prerequisite: Knowledge of compliance program implementation, assessment or monitoring
Field of Study: Behavioral Ethics
On February 8, 2017, the Evaluation of Corporate Compliance Programs (Evaluation Guidance) appeared unannounced on the U.S. Department of Justice (DOJ) Fraud Section’s website. This was the latest addition to the canon of corporate compliance
guidance that includes resources such as the United States Attorney’s Manual, the United States Sentencing Guidelines, the DOJ’s A Resource Guide to the U.S. Foreign Corrupt Practices Act, the OECD’s Anti-Corruption Ethics and Compliance Handbook for Business,
as well as publications from the United Nations Office on Drugs and Crime, and the World Bank.
The Evaluation Guidance notes that the DOJ Fraud Section does not use a rigid formula to assess the effectiveness of corporate compliance programs, as it recognizes that each company has a unique profile and will undertake the appropriate solutions
to reduce its risks. However, the Evaluation Guidance suggests common questions that can be asked to arrive at an individualized determination.
Drawing from the Evaluation Guidance’s main sample topics and questions, this Pre-Conference session will provide you with best practices to evaluate your organization’s corporate compliance program. Major areas of focus include in-depth exploration
of training and communication, confidential reporting and investigations, incentives and disciplinary measures, third-party management, and mergers and acquisitions.
Course Outline:
- Block 1: Performance Incentives That Drive Accountability
- Block 2: Training and Communications to Promote a Speak-Up Culture
- Block 3: Exercising Due Diligence over Third-Party and Merger Transactions
You Will Learn How To:
- Align performance incentives and disciplinary measures resulting from investigations to drive organizational accountability and better manage ethical risks
- Design and implement training and communication programs that effectively promote employee reporting and a “speak-up” culture
- Leverage proactive compliance due diligence during the M&A process to identify pre-merger and post-transaction risks