JM - Society of Corporate Compliance and Ethics

Compliance and Ethics Hotlines... continued from page 13widely promoted as part of communicationand training concerning thecomplaint procedures. Further, periodicmonitoring of the process caninclude evaluating the status ofwhistleblowers after a period oftime to determine if they are experiencingharassment or other punitivemeasures.Reporting Mechanisms for Agents,Suppliers, Vendors, Customers, andInvestorsAnother consideration is promotinguse of the mechanism outside ofthe workforce to meet the requirementsof Sarbanes-Oxley. If thereare other avenues where aSarbanes-Oxley matter can potentiallybe reported (e.g., customercomplaint line), procedures shouldbe developed to ensure that such acomplaint gets forwarded to theappropriate resource, and is includedin information provided to theaudit committee.If a mechanism is promoted for useoutside of the company, proceduresand protocols will need to beassessed. The potential increase inreporting volume will need to beconsidered. Whether or not issuesneed to be routed and handled differentlydepending on who reportsa matter, also should be evaluated.Final ThoughtsThe establishment of formal proceduresfor receiving and handlingcomplaints is intended to facilitatedisclosures and thereby alerting theaudit committee of potential problemsbefore they have serious consequences.Implementing a hotlinemechanism can achieve this objective,but only if it is designed in amanner that encourages its properand effective use.Recently, on November 2004, therevised Federal SentencingGuidelines for Organizations wentinto effect. Although the impact ofrecent U.S. Supreme Court cases,United States v. Booker and UnitedStates v. Fanfan, on the sentencingguidelines is yet unknown, theamendments emphasize having asystem whereby the organization'semployees and agents can "seekguidance" regarding concerns orpotential violations - in addition toa system to just report violationsafter the fact.It is worth noting that the amendmentsto the sentencing guidelinesadd significantly greater stringencyto present day compliance criteriaand therefore, organizations shouldcontinue to monitor developmentsin organizational compliance andcorporate governance, and makepreparations to adjust their complianceprogram (and hotline) as warranted.■Call for Authors!Please email your articles or topic ideas to Compliance &Ethics story editor, Renee Molstad, at renee.molstad@corporatecompliance.org.Be sure to include your telephonenumber or you may call Renee at (888) 277-4977 to discussyour article ideas.Deadlines:■ June 13, 2005 (August issue)■ September 16, 2005 (November issue)■ December 16, 2005 (February 2006 issue)Compliance & EthicsAdvertising ratesFull page B/W insertion rates:1-2 $640.003 - 5 insertions $605.006 - 11 insertions $490.0012 or more $405.00Half page B/W insertion rates:1-2 $450.003 - 5 insertions $420.006 - 11 insertions $355.0012 or more $305.00Quarter page B/W insertionrates:1-2 $265 003 - 5 insertions $250 006 - 11 insertions $225 0012 or more $215.00Full page 2 color insertion rates:1-2 $1075.003 - 5 insertions $1040.006 - 11 insertions $925.0012 or more $840.00Half page 2 color insertion rates:1-2 $885.003 - 5 insertions $855.006 - 11 insertions $790.0012 or more $740.00Quarter page 2 color insertion rates:1-2 $700.003 - 5 insertions $685.006 - 11 insertions $660.0012 or more $650.00February 200514Society of Corporate Compliance and Ethics • (888) 277-4977 • www.corporatecompliance.org