Joe Murphy – Compliance & Ethics Professional – January 2016
A core element of an effective compliance and ethics program is periodic evaluation and review. This point was introduced into the Sentencing Guidelines with the 2004 revisions, but is increasingly found in standards and recommendations around the world. For example, it is one of the 12 items in the OECD’s Good Practice Guidance. Two questions that come to mind are, how often to evaluate and who does the evaluation?
As for frequency, there should certainly be a substantial review by an independent third party at some time in the process. But this misses an equally important point: Evaluation does not require looking at every part of the program every time you conduct a review. Instead, there are multiple elements of your program that can be reviewed.
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