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By Mark Dorosz
VP of Compliance Learning, Interactive Services
The goal of compliance training is to provide managers and employees alike with guidelines to follow in cases of corruption or fraud. But what happens when, despite all the training, the policy is ignored by the company? Anti-Corruption policy is a serious matter that must be addressed head on.
The reasons for this breakdown are varied, and include lack of pre-policy risk assessment, failure to determine how daily routines might affect reporting, and managerial indifference to reporting policies. In order to correct the problem, immediate action is essential.
- Even if no corruption reports have been made to date, monitoring for non-compliance is still essential. Lack of reporting may be a sign of failure of policy, rather than lack of fraud or corruption.
- Internal auditing. Monitoring must include audits and reviews of the compliance program, including support from the top and middle management, and due diligence from outside partners.
- Training updating. Often, compliance failure can be traced to lack of training updates. Too often, compliance training is a once-yearly or biannual event, when it should be quarterly or even monthly. Laws and technology change too quickly for training to lag more than a month behind.
- Reporting and communication channels. Most critically, channels for reporting and communication need to be kept clear and open. Confidentiality is a must, and whistleblower protections have to be articulated and then followed by management and the board.
Compliance in anti-corruption and anti-fraud policy is essential in today’s corporate culture. Continuous training is only a part of the equation. Solid managerial practices and strong board support for whistleblowers is critical to keep the policies and practices flowing smoothly and reliably.
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