Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. In this final episode of our 31-day series, we dive into the importance of using root cause analysis for remediation in compliance programs. Emphasized by the ECCP and DOJ, an effective compliance program includes thorough root cause analysis to address misconduct and implement corrective actions. The process involves understanding who should perform the remediation, emphasizing independence and objectivity, integrating the information into solutions, and addressing deficiencies in internal controls. Key takeaways include using objective root cause analysis, effectively utilizing the information gathered, and implementing data-driven, repeatable solutions to prevent future issues. This episode provides valuable insights for compliance officers aiming to enhance their programs by focusing on root causes rather than just symptoms. Key highlights: Integrating Root Cause Analysis into Solutions Regulatory Expectations and Internal Controls Performing Effective Root Cause Analysis Developing and Implementing Solutions Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 30, we discuss the Foreign Extortion Prevention Act (FEPA), a significant piece of legislation that fills a critical gap in the FCPA. FEPA criminalizes not only the payment of bribes but also the solicitation and acceptance of bribes by foreign officials, thereby providing a more comprehensive framework for combating global corruption. This law protects American workers abroad, promotes fair business competition, and upholds ethical practices internationally. However, it also introduces challenges, such as the complexity of extraditing foreign officials and potential impacts on international relations and companies operating overseas. Compliance officers must reassess internal controls and develop response plans to navigate the implications of FEPA effectively. Key highlights: Filling the Gap in Anti-Corruption Laws Key Features and Implications of FEPA Challenges in Implementing FEPA The Name and Shame List Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. Traditional compliance reporting methods, often reliant on manual processes like Excel spreadsheets, are time-consuming and prone to errors. This episode explores how Chief Compliance Officers and compliance professionals can enhance their programs through automation. By adopting data-driven solutions and leveraging regulatory operations (Reg Ops), it’s possible to provide near real-time reporting and improve decision-making efficiency. The focus is on integrating existing security and compliance tools, gathering real-time evidence, automating compliance gap tickets, and generating comprehensive reports for stakeholders. However, challenges like balancing data accuracy and security and the cultural transformation required for adopting these new practices are critical considerations. Embracing data-driven compliance can help organizations modernize and keep pace with the evolving regulatory landscape. Key highlights: Challenges in Traditional Compliance Reporting The Role of Reg Ops in Compliance Integrating Tools for Real-Time Compliance Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 28, we look into the crucial importance of data governance in compliance and cybersecurity. As data generation increases, businesses must enhance their efforts in managing, organizing, and preserving data to meet regulatory obligations and ensure accuracy, accessibility, and adherence to legal standards. We discuss the growing trend of converging compliance, data governance, and cyber security and the necessity of breaking down organizational silos for effective collaboration. Business and legal teams rely on well-managed data to make informed decisions, analyze trends, and measure key performance indicators. The episode also covers the challenges in gaining buy-in from the ELT and the vital process of transforming corporate culture to prioritize data governance and cybersecurity. We touch on the complexities of regional data privacy laws inspired by GDPR and emphasize the importance of understanding specific regulations for compliance. With key takeaways, including the significance of data preservation, the intertwined nature of compliance, data governance, and cybersecurity, and the urgency for organizations to prioritize data governance, this episode is packed with essential insights for compliance professionals. Key highlights: The Role of Data Governance in Compliance and Cybersecurity Data Governance and ESG Understanding Data Privacy Laws Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 27, we explore the growing importance and responsibilities of the compliance function within corporations, emphasizing the need for adequate staffing, resources, and independence. The 2020 FCPA Resource Guide outlines key factors that the DOJ considers indicative of an effective compliance program, including the quality of personnel, authority, compensation, and reporting structure. We delve into the necessity of properly funding compliance initiatives and ensuring the organization empowers and sufficiently supports compliance professionals. The updated Corporate Enforcement Policy emphasizes the prevention of retaliation against compliance investigators and the need for a robust structure supporting the compliance program. We conclude with three key takeaways for enhancing compliance functions: evaluating their treatment in the budget process, ensuring management respects compliance decisions, and considering the implications of outsourced compliance services. Key highlights: DOJ’s Expectations for Compliance Programs Funding and Resources for Compliance Compliance Program Structure and Authority Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 26, we ponder the evolving stature and authority of the CCO within organizations, as highlighted by recent guidelines and regulations. The 2020 FCPA Resource Guide emphasizes the importance of the CCO’s direct reporting line to the board and senior management status. The DOJ’s updated Corporate Enforcement Policy has further enhanced the prestige and role of the CCO, introducing key factors like the quality, experience, authority, independence, compensation, and reporting structure of the CCO. The episode also touches on the significance of the Delaware Court of Chancery’s decision in the McDonald’s case, which formalized the oversight duties of corporate officers, positioning the CCO as the second-most important role in an organization. Key takeaways include demonstrating real authority for the CCO, evaluating their professional qualifications, and assessing their actual status within your company. Key highlights: Key Inquiries Around the CCO and Compliance Function Importance of CCO Certification and Court Decisions Critical Takeaways for Compliance Professionals Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 25, we consider the critical importance of addressing investigative findings within a corporate compliance framework. When a whistleblower report, DOJ subpoena, or SEC notice brings compliance violations to light, it commands the board’s and senior management’s attention. The initial outrage and ethical proclamations that follow are often a prelude to the need for a serious reality check regarding costs and time outlays for remediation. The key is maintaining transparency and solid communication between those investigating and those responsible for remediation, ensuring compliance gaps are effectively identified and addressed. Today’s takeaways emphasize using the heightened attention for compliance improvement, recognizing the interplay between investigation and remediation, and being ready to answer the ‘where else’ question effectively. Join us tomorrow as we explore the authority and independence of Chief Compliance Officers. Key highlights: The Impact of Investigations on Compliance Communicating Costs and Risks Ensuring Effective Communication Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 24, we look into the critical internal reporting process and triaging of FCPA claims. As the CCO, you will oversee the initial steps when suspicious activities are reported. Jonathan Marks’ five-step process on early assessment of incoming information is explored, providing a structured approach for evaluating the severity of allegations from low-threat level to crisis management mode. Moreover, this episode emphasizes the necessity of effective hotlines, trained managers, and a culture of listening to employees to foster a safe reporting environment. Key takeaways include the DOJ and SEC’s emphasis on internal reporting lines, regularly testing hotlines, and the triage of claims to ensure appropriate investigation levels. Key highlights: Guidelines for Effective Compliance Programs Jonathan Marks' Five-Step Process for Early Assessment Key Takeaways Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 23, we delve into the essential steps for conducting a thorough and effective internal investigation following an internal report. The discussion is grounded in the ECCP’s guidelines, emphasizing the necessity of properly scoping investigations with competent personnel and adequate resources. A detailed written procedure is crucial for handling complaints or allegations of bribery and corruption, regardless of their origins. The episode outlines a five-component investigative protocol: opening and categorizing the case, planning the investigation, executing the investigative plan, determining appropriate follow-up, and closing the case. Emphasis is placed on maintaining transparency, consistency, and thorough documentation throughout the process. Three key takeaways are highlighted: the importance of a written protocol, the need for transparency and documentation, and the critical role of consistency across the organization. Key highlights: Key Questions for Internal Investigations Detailed Procedures for Handling Complaints Steps in the Investigative Process Importance of Consistency in Investigations Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 22, we consider the levels of due diligence you should use when investigating third parties. Tom outlines the three due diligence levels necessary to manage corruption risk effectively. With insights from Candice Tal, founder and CEO of Infortal, Tom breaks down each level in detail, from initial screenings in level one to comprehensive, on-the-ground investigations in level three. He emphasizes the need for tailored approaches based on the risks associated with different business transactions and the importance of thorough documentation throughout the process. Key highlights: What are the levels of Due Diligence? When is each level appropriate? Key Takeaways Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. On Day 21 of our series, we dive into the essential strategies for managing third-party relationships in a compliance program. We consider the significance of a structured and strategic approach in handling third parties to mitigate anti-corruption risks. As companies mature, the operationalization of compliance through third-party management becomes crucial. Key areas explored include the importance of dual and diversified sourcing, monitoring subcontractors, legal protections, and financial stability checks. Additionally, we cover the necessity of integrating performance-based compensation and regular auditing to uphold compliance standards. Join us tomorrow as we explore levels of due diligence on Day 22. Key highlights: Strategic Approach to Third-Party Relationships Auditing and Ongoing Management Key Takeaways Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.  On Day 20, we delve into the third-party risk management process, a crucial aspect of corporate compliance under the FCPA. Third parties continue to pose the highest risk, necessitating an integrated and operational approach throughout the company. The episode outlines the five essential steps in the third-party risk management life cycle, as mandated by the DOJ in the 2020 FCPA Resource Guide. These steps include business justification, third-party questionnaires, due diligence, compliance terms and conditions, and post-contract management and oversight. Each step is explored in detail, emphasizing the importance of documenting business cases, performing thorough due diligence, and maintaining diligent oversight to mitigate potential FCPA violations. Key takeaways include the necessity of using the full five-step process, involving business development and ensuring all steps are operationalized with business unit representatives. Join us tomorrow for Day 21 to discuss managing your third parties. Key highlights: Introduction to Third Party Risk Management The Five Steps of Third-Party Risk Management Key Takeaways  Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.  In today's episode, we review the critical process of evaluating and translating risk assessments into actionable risk profiles. The discussion highlights the importance of prioritizing risks based on their significance and likelihood using risk matrices and heat maps. Expert insights from Ben Locwin and Bill Anathas emphasize focusing resources on high-risk employees and maintaining a robust compliance program aligned with FCPA guidelines. The episode also covers the Treasury Department's OFAC compliance framework and offers concrete steps for continuous risk monitoring and remediation. Key takeaways include the necessity of a well-reasoned approach to risk evaluation, thorough documentation, and the implementation of a dynamic risk matrix to guide compliance efforts. Key highlights: ·      Understanding Risk Profiles ·      Evaluating Risk Management Processes ·      Risk Matrix and Heat Maps Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.  In this episode, we discuss the essential role of risk assessments in anti-corruption compliance programs. A well-structured risk assessment forms the foundation of every corporate compliance program. We explore how organizations should identify, assess, and define their risk profiles, emphasizing the need for annual risk assessments whenever business risks change. The focus then shifts to geopolitical issues, supply chain dynamics, and evolving work environments and how these should be factored into compliance risk assessments. Historical perspectives from DOJ guidelines and the importance of a robust risk identification, analysis, and management methodology are also discussed. As highlighted, documenting these processes is crucial for developing an effective compliance strategy that evolves with the company’s risk landscape. Finally, the episode outlines the steps to create a comprehensive risk management strategy post-assessment, including policy development, training, monitoring, and updating protocols. Key highlights: The Importance of Regular Risk Assessments Methodologies for Risk Assessment Steps in Conducting a Risk Assessment Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance.  In this episode, we explore the transformative potential of podcasting in compliance training and fostering corporate culture. Harnessing the power of imaginative communication methods, we discuss the effectiveness of delivering compliance messages and training through various podcast formats. We revisit the 2012 Morgan Stanley declination to underscore the impact of consistent compliance reminders and venture into how short ethics and compliance video clips and storytelling podcasts can enhance employee engagement and regulatory satisfaction.  These podcasts are standalone training tools and can be broadcast through social media, creating a larger reach and providing valuable feedback through listener engagement metrics. Additional formats discussed include a branded podcast series featuring longer episodes that humanize compliance topics through interviews and a daily compliance news show to keep employees informed and engaged. This episode emphasizes the importance of innovative storytelling in making compliance communications memorable and effective. Key highlights: ·      Podcast Storytelling: A New Approach ·      Branded Podcast Series for Compliance ·      The Benefits of Podcasting for Compliance Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be 6-8 minutes short, with three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. In today’s episode, we delve into the evolution and importance of employee compliance training, focusing on fostering a culture of compliance within organizations. We discuss key guidelines from the FCPA Resource Guide 2nd Edition and subsequent updates from the DOJ and SEC, emphasizing the necessity of effectively communicating and tailoring training programs to an organization’s specific audience. Critical aspects include the importance of training in local languages, assessing the risk profile of employees, and ensuring senior management’s participation. Furthermore, we explore the concept of ‘espresso shots’ or concise training segments to enhance learning and retention. Metrics such as increased hotline use and survey feedback are essential for evaluating the effectiveness of compliance programs. Key highlights: Evolution of Compliance Training Standards Measuring Training Effectiveness Tailoring Training to Audience Needs Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. In this episode, we look at the ongoing process of monitoring and improving company internal controls. Christina Ravelo starts by posing fundamental questions about the frequency of manual approvals and control overrides, emphasizing the importance of continuous evaluation and recalibration. This episode highlights the misperception among many compliance professionals and lawyers that controls are static and unchanging once implemented. Instead, internal controls should be dynamic, requiring regular reviews and updates based on collected data, such as the frequency of overrides. Proper documentation is crucial, and companies should engage in periodic self-reviews as part of their continuous monitoring efforts. Ravello also stresses the necessity of identifying issues and remedying them to prevent further complications. Today’s key takeaways include the idea that control overrides are not inherently problematic if appropriately managed, the dynamic nature of internal controls, and the importance of a comprehensive monitoring process incorporating feedback from every line of defense. Key highlights: Understanding Control Overrides Continuous Monitoring and Improvement Assessing and Updating Controls Resources: Click here to receive a 20% discount on The Compliance Handbook, 5th edition, for listeners to this podcast. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. Today, the focus is on internal controls and their critical role in compliance frameworks. The episode provides a comprehensive definition of internal controls, emphasizing their importance for achieving operational efficiency, reliable financial reporting, compliance with laws and policies, and the reduction of risks such as fraud and waste. The discussion highlights the requirements outlined in the FCPA for internal controls, including the authorization and documentation of transactions and the protection and accountability of assets. Moreover, four significant internal controls for compliance practitioners are identified: delegation of authority, maintenance of the vendor master file, contracts with third parties, and management of cash and currency transfers. The episode underscores that effective internal controls are essential and mandated by the FCPA, forming a cornerstone of any robust compliance program. Key highlights: Defining Internal Controls Key Components of Internal Controls Internal Controls in Compliance Programs Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. In this episode, we review the importance of having well-crafted compliance policies and procedures as the foundation of a robust compliance program. As highlighted by the 2024 ECCP and 2020 FCPA Resource Guide, such policies and procedures are crucial for addressing and mitigating risks identified during a company’s risk assessment. Regulators emphasize having articulated anti-bribery and anti-corruption policies regularly reviewed and updated to reflect evolving risks. We discuss the five general elements of a compliance policy and underscore the need for consistent implementation to maintain the credibility and effectiveness of the compliance program. Key takeaways include the necessity of written policies, expectations from the DOJ and SEC, and the critical role of institutional fairness. Key highlights: Importance of Compliance Policies Key Elements of Compliance Policies Assessment and Evolution of Policies Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will include three key takeaways you can implement at little or no cost to help update your compliance program. I hope you will join us each day in January for this exploration of best practices in compliance. This episode explores the critical value and construction of a corporate Code of Conduct, explaining its evolution from a legalistic document to a cornerstone of compliance programs. The discussion includes an analysis of the 2016 SEC Enforcement Action against United Airlines, highlighting how violations of the Code of Conduct can lead to severe consequences, including substantial penalties and executive resignations. Key takeaways emphasize that a Code of Conduct should be tailored to a company’s specific culture and industry, must be accessible to all employees, and needs to be regularly updated and documented to ensure its effectiveness. Tune in to learn why a robust Code of Conduct is foundational for any compliance program. Key highlights: Introduction to Code of Conduct Regulatory Expectations and Guidelines Crafting an Effective Code of Conduct Resources: Listeners to this podcast can receive a 20% discount on The Compliance Handbook, 5th edition, by clicking here. Learn more about your ad choices. Visit megaphone.fm/adchoices