We often hear about the “essential” elements of an effective ethics and compliance programs. It is natural for professionals to define specific elements of an ethics and compliance framework. This is an important way to break down a program for assessment purposes.
While analyzing the specific functions in a program, it is important to avoid a narrow review of each element. Instead, as in most issues, the analysis of each element has to incorporate a factor that captures the interdependency of various elements. For example, the effectiveness of one element may enhance or improve the operation of another element. A simplistic way to express this idea is — the whole is often larger than the sum of the parts.
In practical terms — an example is the interdependency of employee reporting systems, investigations and specific training programs. Let’s start with the reporting system. There is no question that a company’s compliance program operates more effectively when the company maintains an efficient and trusted mechanism to report allegations of misconduct (either anonymously or confidentially). As part of this element, a company has to embed multiple avenues for employee reporting of potential misconduct, publicize the reporting avenues to increase reporting, and train managers on how to respond to employee concerns when directly raised by employees. When all three of these sub-elements are operating effectively, the sum of the overall performance will exceed the performance...
Patrick Brown has been mayor for almost eight years and one of the many promises he has failed to keep is the one that angers Brampton voters more than any other. For almost a decade he has claime...