“A company’s code of conduct is often the foundation upon which an effective compliance program is built.”~ A Resource Guide to the U.S. Foreign Corrupt Practices Act
THEN GENESIS OF A WRITTEN CODE
TALE OF TWO CODESPAST & CURRENT BEST PRACTICES
USER-FRIENDLY CODES THAT HELP MITIGATE RELEVANT RISKS
Tone from the Top
Readability & Tone
Reporting & Non-Retaliation
Values Statements &Stakeholder Commitment
All Relevant RiskTopics Coverage
Learning Aids
Accessibility:Internally and Externally
Presentation. Style. Organization.
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Collection/summaries of corporate policies
Legalese, unapproachable content
Impersonal messaging and tone
Overly general coverage of risk topics
MEETING REQUIREMENTSEmployees should strive to avoid even the appearance of a conflict of interest by avoiding associations or investment interests that interfere, might interfere or might appear to interfere with the independent exercise of judgement in [Redacted] best interests.
NOW CULTURAL AWAKENING
INCREASING EMPLOYEE ENGAGEMENT LEADS TO BETTER RESULTS IN A
COMPLIANCE PROGRAM
9 sec.Average Attention Span of a GoldfishAverage Attention Span in 2013
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