Joe Murphy – Compliance & Ethics Professional – March 2014
You have worked your way through your compliance program checklist to the end. Whatever list you are
using (OECD Good Practice Guidance, Federal Sentencing Guidelines, Canadian Competition Bureau’s Bulletin, etc.), you think you have covered the list. So why can’t you find someone who will tell you that you are done? Management has other work for you, once you have finished your seven, or ten, or other number of steps. When can you stop?
Here’s the simple answer: Never. Never?? Right, no matter what you do, you are never done. Why?
Because a compliance and ethics program is not a model ship that you finish and put on the shelf. Think about the purpose of the program. It is to prevent and detect misconduct. You are shooting at a very difficult, moving target. Those determined to break the law can be extremely clever. They are always working at it. Their methods are always evolving.
. . .