Discipline for “failure to take reasonable steps”: Could you find even one example in your company?

Discipline for “failure to take reasonable steps”: Could you find even one example in your company?

Joe Murphy – Compliance & Ethics Professional – May/June 2013

discipline

There are certain parts of the Federal Sentencing Guidelines standards most folks seem comfortable with (e.g., codes of conduct, training, helplines). And then there are topics that it seems almost no one is comfortable with. One example is discipline—not many articles or presentations on that.

So here is an issue I just don’t see discussed. The Guidelines very clearly call for:

“(B) appropriate disciplinary measures for… failing to take reasonable steps to prevent or detect criminal conduct. (emphasis added)

It is right there, in black and white, clear as day. Our Canadian friends, in their Competition Bureau’s guidance on compliance programs, also say:

. . .

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