Compliance & Ethics Professional - Society of Corporate ...

future violation that comes with placing aknown or suspected violator in a positionof discretionary responsibility.··Oversee the background investigations ofapplicants/employees/members who arebeing considered for positions of discretionaryresponsibility.Communicate the organization’s standardsand procedures, ensuring the effectivenessof that communication.··Determine the mechanisms for communicatingthe organization’s ethical standardsand procedures.··Develop and distribute appropriate documentsand/or underwrite training, toensure that all employees know andunderstand the standards and procedures.··Develop mechanisms, such as needs analyses,to identify employees’ or members’areas of concern or confusion.··Coordinate policies to ensure that the messagescontained in them are not in conflictwith one another.··Recognizing that communication is twoway,determine mechanisms for solicitingstakeholder input into how standards andprocedures are defined and enforced.··Develop certification mechanisms toensure that the organization has evidencethat each employee has received the appropriateinformation and understands thestandards and procedures they describe.··Create mechanisms (such as ombudsmanoffices or employee hotlines) tofacilitate employees receiving “safe”guidance and/or policy interpretationand to ensure each employee’s access to a“safe” mechanism for reporting suspectedwrongdoing.··Determine what training is necessary foroptimum compliance levels with the publishedstandards and procedures.Monitor and assess compliance.··Develop the internal control mechanismsnecessary to demonstrate individual andorganizational compliance with the publishedstandards and procedures.··Develop mechanisms to demonstrate theeffectiveness and reliability of the internalcontrols.··Develop mechanisms to assess the compliance-relatedrisks associated with theorganization’s strategic and operationalgoals, objectives, and plans.··Develop mechanisms to ensure that formalizedmeasurements and rewards donot motivate noncompliance with the organization’sstandards and procedures.··Develop and support whatever additionalreporting mechanisms are deemed necessaryto effectively monitor and assesscompliance with the organization’s standardsand procedures.Oversee enforcement, including the assurancethat discipline is uniformly applied.··Develop mechanisms to ensure consistentdisciplinary responses for essentially similarviolations (i.e., ensure that there are notdifferent standards applied for differentemployees based on position, performance,function, etc.).Compliance & Ethics Professional March/April 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 51