Evaluating your compliance program: The “deep dive”

Evaluating your compliance program: The “deep dive”

Joe Murphy – Compliance & Ethics Professional – April 2016

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Evaluation is essential for an effective compliance program. There is, however, a risk that we will measure what is most measurable and use the tools that lead to the most quanti able results. It is certainly easier to assess by surveys how many employees say they feel good, bad, or indifferent than is it to dig down to discover whether anyone is actually engaged in accounting fraud, corruption, or price-fixing.

On the other side of the spectrum, auditing is a tool that involves deeper reviews, including testing what employees are actually doing on the job. Audits, however, come with their own baggage; there appears to be an enduring resistance to an assessment device that is perceived as negative and, by some, as a checklist exercise. This perception may be outdated, but remains an obstacle.

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