The Six Elements of an Effective Compliance Program: 5 – Oversight and Reporting and Response and Enhancements

Welcome to a special five-part podcast series, The Six Elements of an Effective Compliance Program. This podcast series is sponsored by StoneTurn. To celebrate Corporate Compliance and Ethics Week, we will consider each of the six elements required for an effective compliance program. They include: Risk Assessment, Governance and Structure, Policies Procedures and Controls, Training and Education, Oversight and Reporting, and Response and Enhancements. Over this five-part podcast series, I will be joined by Stephen Martin and Valerie Charles, Partners at StoneTurn and Toby Ralston and Jamen Tyler, Managing Directors at StoneTurn. In this fifth episode, I visit with Valerie Charles on the twin topics of Oversight and Reporting: The Board’s Role in Compliance and Having a Speak Up Culture and Response and Enhancements: Continually Improving Your Compliance Program. Highlights include: 

Oversight and Reporting-the Board’s Role in Compliance and Having a Speak Up Culture

• What is the relationship between whistleblowers/hotlines/internal reporting/Speak Up culture and Internal Investigations?
• 3Rd Parties are still the highest FCPA risk. How and why has Due Diligence become even more important in the era of Covid-19.
• How should a CCO educate the Board on their role within the Compliance framework?
• How does a Board walk that fine line between management and oversight?
• What types of questions should a Board be asking a CCO?

Response and Enhancements- Continually Improving Your Compliance Program

• What are some of the key elements of Third-Party Risk Management?
• In the 2020 Update, the DOJ strongly emphasized not simply oversight but continuous monitoring and continuous improvement. How can a CCO think through continuous monitoring and then using that information to improve a compliance program?
• What are some strategies for Continuous Monitoring?
• The 2020 Update mandated greater use of data by a CCO. Yet even with data, why is the human element so critical in any data-based solution?
• Root cause analysis is now a separate Hallmark of an Effective Compliance Program. How should a CCO use root cause analysis in response and enhancements?

Resources

For more information on StoneTurn, click here.