Joe Murphy – Compliance & Ethics Professional – March 2016
Often even those who are experts read things, and because of their pre-conceptions, ignore what is written there. It happens all the time in the Federal Sentencing Guidelines. And it has happened in another critically important source of compliance advice, the Good Practice Guidance (GPG) provided by the OECD’s Working Group on Bribery.
I understand the desire to simplify and pigeonhole. So when the GPG 12 points on compliance programs included coverage of advice and reporting systems, many read this as being the same as the Sentencing Guidelines provision.
But there is some important wisdom in the language of item 11 of the GPG. There is not just a need to have a means to provide advice. It must also include a system for providing that assistance to your people “when they need urgent advice on dif cult situations in foreign jurisdictions.”
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