This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am joined in this exploration by Russ Berland, a well-known compliance commentator and practitioner who recently joined Dematic Inc., a Supply Chain optimization company, as it CCO. Today I want to explore how the Human Resources (HR) department can be used to more fully operationalize compliance beyond simply considering the lifecycle of the employment relationship.

Berland had some interesting thoughts on the role of HR in compliance, stating, “The areas though that I think HR can be really, really good at, that as an opportunity that they wouldn’t view as a compliance opportunity, is they know when there are problem groups. They know where there are people who distrust their leadership, or that leadership is isolating the group from the rest of the company.”

Often HR will attempt to deal with the issues through the mechanism of a HR toolkit approach. They will counsel, they will train or retain, they will keep up an ongoing dialogue through communications. HR may also move to other tools such as a performance review. However it may be that the HR toolkit is really not equipped to deal with certain situations and fact patterns. Berland said, “Often those are tremendous red flags that there are compliance issues that are coming up within that organization. That’s where having that constant communication between compliance and with HR is of real benefit because I’ve gotten phone calls before from a HR person that says “We don’t know what’s going but, man, this group is a mess!” And you know? You start talking to them and asking questions and realize there’s probably some vendor conflict of interest issues that this guy’s trying hide and protect, and it’s just affecting negatively the entire group.”

Such an approach can also be used in the area of conflicts of interest (COI). Such an approach can handle more minor  COI’s, such as the relationships between people in a department or it can expand to larger and potentially more serious COI’s, such as kickbacks from vendors and suppliers. As the corporate function on the front line of dealing with people, HR should be in a role to be able to see at least outcomes from people are acting in certain ways, not with transparency, allowing it to be the first line defense in terms of evaluating and addressing such conflicts of interest.

Where HR can take the lead in many such areas, it would have the effect of further operationalizing your compliance program; as it is  really the co-worker who is probably the closest and who will pick up the phone and talk to someone from HR. While it may take some specialized training from compliance to bring HR up to a compliance standard I would argue that the effective use of such training can extend far beyond the limits of HR and, more importantly, the resources of the compliance department.

For strategic planning around compliance, HR is a key stakeholder as compliance builds out its program for effectiveness and efficiencies. Berland related, “I wouldn’t even consider doing strategic planning for a compliance function without having HR in the room, just like I would expect to have legal in the room and internal audit in the room. They are key stakeholders. They need to have input into what compliance is doing and how it’s doing it. It also gives them visibility to understand where the points of interface are. It has always been more successful having those folks involved, just as a matter of nuts and bolts practice.”

This can also extend to policies and procedures. Every company has a large number of HR policies and procedures so why not bring some of that expertise and resources to the compliance function as well. There is no legal reason why these two functions should not be working together. Indeed, the Depart Of Justice (DOJ) Evaluation of Corporate Compliance Programs (Evaluation) asks following questions in Prong, “Responsibility for Integration Who has been responsible for integrating policies and procedures? With whom have they consulted (e.g., officers, business segments)? How have they been rolled out (e.g., do compliance personnel assess whether employees understand the policies)?”

An area not often considered in the intersection of compliance and HR is remediation. This is not simply termination, as two of the questions posed in the Evaluation are: “Human Resources Process – Who participated in making disciplinary decisions for the type of misconduct at issue?” and Consistent Application – Have the disciplinary actions and incentives been fairly and consistently applied across the organization?” If the solution is something other than termination, what is the remediation solution and who will deliver it and follow up to determine its effectiveness? Once again HR is uniquely suited to deliver what might otherwise be considered a compliance solution. Berland stated, “HR is going to be right there with those people where compliance has probably moved onto something else. They’re going to be able to see that everyone’s taken whatever remedial training they’re supposed to, that whatever changes in the management approaches have been implemented, and they can really keep their finger on that pulse.”

Finally we have the area of whistleblowers, most specifically around retaliation. While there was the recent example at Barclay’s where the chief executive attempted to ascertain the name of an anonymous whistleblower, the usual path is that a whistleblower is figured out by their co-workers or through the allegations under investigation. Once again HR is uniquely suited to recognize retaliation, warn and train against it, protect the whistleblower and then work with compliance throughout the process.

The bottom line is that HR will have a strong network throughout an organization. Compliance can learn about delivery techniques and mechanisms in areas such as training. More importantly, with HR personnel, particularly those positioned around the world who understand how compliance issues impact them, the ways in which they can cooperate, extends the reach of compliance and more fully integrates compliance into an organization. Put another way, operationalizing compliance in this manner by having more people who are aware of the issues that are facing them and are points of contact for them, can only strengthen compliance.

Tomorrow I will consider how the compliance function can use internal audit to further operationalize a compliance program.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2017

The Evaluation of Corporate Compliance Programs document makes clear that operationalization of compliance into an organization should be done at multiple levels in a company. Creating an ethical culture is an important step for any company to burn compliance into the DNA of a business. It must be done at every level of an organization on a continuous basis.

In an article in the Harvard Business Journal (HBJ) online publication by Christopher McLaverty and Annie McKee, entitled “What You Can Do to Improve Ethics at Your Company”, the authors surveyed C-suite executives and noted, “More often the dilemmas were the result of competing interests, misaligned incentives, clashing cultures.” Based on this study and their prior work, the authors noted three major obstacles to ethical behavior.

Initially was the issue of corporate change. The authors stated, “Companies can warp their own ethical climate by pushing too much change from the top, too quickly and too frequently. Leaders in the study reported having to implement staff reduction targets, dispose of big businesses in major markets, and lead mergers and acquisitions. Some of these activities included inherent conflicts of interest; others simply caused leaders to have to act counter to their values. Many leaders felt poorly prepared for the dilemmas they faced and felt compelled to take decisions they later regretted.”

The second was the age old dilemma of compensation where incentives tended to drive certain behaviors or, as the authors stated, “People do what they are rewarded to do, and most leaders are rewarded for hitting targets.” Of course the most recent example is Wells Fargo where employee compensation was based solely on the number of accounts they opened. Yet such incentive based behavior was not limited to front line employees as the authors stated, “The lure of incentives are a problem in boardrooms too: Bonus payments and executive share schemes are often based on short-term business metrics, which can be counter to long-term success.”

Finally, was an area which may require a Chief Compliance Officer (CCO) or compliance practitioner to think through several different calculi; cross cultural differences. Obviously some countries have gift giving cultures but this is more than simply the value of a gift to give at Christmas, it involves cultures where gift giving may be a part of the overall business relationship. The authors cited examples such as “closing a sales office in Japan, breaking a verbal promise made during after-work drinks in China, or ignoring “sleeping” business partners in a Saudi Arabian deal, all of which have cultural and ethical components.”

An interesting insight was teaching employees how to understand what matters in an organization. This is not simply the written Codes but how things really work. The authors posited three questions: (1) How are employees paid? Obviously a compensation plan is a critical benchmark. If it is solely based on ‘eat what you kill’, focusing on the short term, it may presage problems down the road. (2) Who gets promoted and why? This is not simply whether the high producer gets promoted but how about those who speak up and raise ethical issues. Are they subtly (or not so subtly) discriminated against or held back from promotion? (3) How do employees feel about their organization? Although it seems straight-forward, if your employees are disengaged or worse yet, ashamed about your company, you might be an ethical time bomb waiting to happen.

The authors then turned to initiatives that the interviewees had successfully used in their own organizations to improve the ethical climate. While noting that there is some importance in the corporate governance documents, such as a Code of Conduct and policies and procedures, the authors averred “Companies become ethical one person at a time, one decision at a time.” This means employees need to understand their organizations underlying culture. They stated, “Self-awareness enables you to build and strengthen that inner compass. Organizational awareness enables you to identify the forces in your company’s culture and processes that could drive you and others to do the wrong thing. You also need emotional self-control: it takes courage to step away from the crowd and do the right thing.”

To have such courage, the authors noted many employees who did speak up had a personal network which operates as “an informal sounding board and can highlight options and choices that the leader may not have considered. When making ethical decisions, it’s important to recognize that your way isn’t the only way, and that even mandated choices will have consequences that you must deal with.” This is yet another reason for the breaking down of silos in a corporate organization because “The challenge is that most leaders have networks full of people who think and act like them and many fail to seek out diverse opinions, especially in highly charged situations. Instead, they hunker down with people who have similar beliefs and values. This can lead to particularly dire consequences in cross-cultural environments.”

Finally, and perhaps most intuitively, is speaking up. Here business leaders must encourage not only a speak up culture but also one of no retaliation. But it is more than this as Vanessa Rossi, FCPA Due Diligence Counsel at Baker Hughes Inc. noted in a panel discussion to the Greater Houston Business and Ethics Roundtable, it is more tones at the tops as for many employee’s senior leadership resides in the form of their direct manager. The authors phrase it as “If you find you need to speak up, there will be a number of choices to be made. Do you talk to the boss? Consult with peers? Work with advisory functions such as legal, compliance or human resources? You can draw on your personal network for support and guidance on the right way forward within the context of your unique situation.”

Ethics and compliance blend together in the corporate world. It is not just the responsibility of CCOs and compliance practitioners but of senior managers to support those employees who want to do the right thing. While written protocols are significant in both detection and prevention, one should never lose sight of a corporate culture as a way to positively impact your workforce and company going forward.

Three Key Takeaways

  1. Beware of the three obstacles to creating an ethical culture.
  2. What really matters in your company?
  3. A speak up culture will improve the operational performance of your business.

 

This month’s series is sponsored by Advanced Compliance Solutions and its new service offering the “Compliance Alliance” which is a three-step program that will provide you and your team a background into compliance and the FCPA so you can consider how your product or service fits into the needs of a compliance officer. It includes a FCPA and compliance boot camp, sponsorship of a one-month podcast series, and in-person training. Each section builds on the other and provides your customer service and sales teams with the knowledge they need to have intelligent conversations with compliance officers and decision makers. When the program is complete, your teams will be armed with the knowledge they need to sell and service every new client. Interested parties should contact Tom Fox.

This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am joined in this exploration by Russ Berland, a well-known compliance commentator and practitioner who recently joined Dematic Inc., a Supply Chain optimization company, as it’s CCO. Today I want to discuss some of the obstacles you may face to operationalizing your compliance program and what you might do to overcome them.

Incentive and Metrics

It is often noted that what is incentivized in a corporation is what takes priority to be accomplished and what is measured is what gets done. This may mean that within your organization, performance metrics are creating corporate silos. Berland contrasted the overall benefits of compliance with more measured goals by noting, “If you’re talking about something that would have a long-term benefit to your group, benefit other groups, benefit the company itself, but not go into your performance evaluation, or to your group’s performance evaluation, those things tend to get shuffled to the bottom of the pile.” This can lead people to understand and even admit that overall compliance health is “a really good idea, we ought to pursue that, but I’ve got certain metrics I’ve got to meet today, and this week, and this month, and this quarter,” and those become the laser beam focus of the group.”

To overcome this short-term thinking, senior management must be able to give disparate functions within an organization, the guidance of strategies the business should follow. The creation of a compliance charter to provide roles, responsibilities and accountabilities is one response of a CCO. Such an approach could occur through compliance strategic planning with senior management so there exists a mission statement to guide the process going forward.

It can also lead to a matrix determination of who within an organization might be best suited to operationalize compliance within the company. Berland believes that by considering “who has ultimate responsibility? Who has accountability? Who needs to be consulted? Who needs to be informed?” you can create an effective and efficient way to determine where an operationalized issue may best be handled. Berland when on to point out, “When you have a written memorandum or understanding after you spend time building out a RACI, then it’s pretty easy. Just look on the matrix and go.”

From such a document, you can determine not only which corporate function should handle the area but also which corporate area should be held accountable going forward. This allows the compliance function to deliver as much assistance to the proper corporate function as is warranted. He cautioned this is not a static document but dynamic based on the issues which arise, stating, “It’s a constantly evolving document as new issues come up, or new problems or tasks come up.”

Inertia

An even more pedestrian problem is corporate inertia as corporate employees simply get used to performing tasks the same way and it is too easy simply not to change. How many times have you, as a CCO or compliance practitioner, heard something along the lines of “But we have always done it that way”? Berland noted, “We tend to drill holes exactly where we’re standing. I don’t think of them as silos, I think of them as pits. You know? Everybody’s building their own foxhole and there’s no way of connecting them.” By this he meant that “if you’ve been doing the same task over and over again for two years, it’s difficult to see beyond that. Being able to kind of pull your head up and look around and say, “Wait a minute, there’s better ways of doing this,” that’s a real skill and not everybody has that in the same measure.” Operationalizing compliance may take some time because of this type of resistance but that is where the pizza comes in so handy. Both the pizza you previously bought and the pizza you will purchase going forward.

Firefighting

In many corporations, the front line or even second or third lines within an organization are simply too busy to consider adding compliance to their portfolios because they are so busy putting out the daily, weekly or larger fires which always seem to arise in the corporate world. There are some employees who simply lack organizational skills to do work in any other manner except constant firefighting but most often it boils down to a lack of resources. This can even impact the compliance practitioner who is trying to devolve their compliance portfolio into other corporate disciplines.

From the CCO or compliance practitioner perspective, Berland conceded “That’s got to be one of the toughest things there is for a compliance person, for two reasons: one is because there’s someone screaming that something has to happen immediately, and the second is those fires tend to be sort of the sexier events.” On the former Berland noted, “Executives have focused on this task and we need to be able to report to the board in two weeks on it. That’s the stuff that gets your adrenalin going, and so it’s certainly easy to do that.” An internal investigation can also meet this description, particularly if the compliance professional is a lawyer; investigations are simply more interesting.

When it comes to operationalizing compliance, through a thorough understanding of the root cause of the process, as Berland noted “When it gets to the harder part it’s the stuff that … Again, it tends to slip to the bottom of pile.” Execution is where the rubber meets the road in compliance and if you cannot put the appropriate controls in place to do compliance because you do not know what they should be or do not have time to perform a gap analysis and remediate them, it stops the operationalization of your program.

Tomorrow I will consider how a Human Resources department could operationalize a best practices compliance program.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2017

The exit interview can be a further mechanism to operationalize compliance. This type of interview is used when someone voluntarily departs from a company, as opposed to a lay-off or reduction in force exercise. Typically departing employees are more willing to share about their experiences, concerns and issues which led to their employment departure.

In an article in the Harvard Business Review, entitled “Making Exit Interviews Count, authors Everett Spain and Boris Groysberg demonstrate that exit interviews, when conducted with care, can be a very useful tool in two important areas: to increase employee engagement, to reveal what may not be working in the organization. These points speak directly to operationalizing compliance through Human Resources (HR). Exit interviews can provide insight into what employees are thinking, reveal problems in the organization, and shed light on the competitive landscape. They believe that companies should focus on six goals in their exit interviews, that there must be an emphasis in both “tactics and techniques” and, finally, that the process is a continuing conversation.

Uncover issues. Organizations “that conduct exit interviews almost always pursue this goal but often focus too narrowly on salary and benefits.” The problem with this approach is that salary concerns are not usually what drives employees to seek employment elsewhere. It is almost always something else. The article stated, “One leader from a food and beverage company told us that exit interviews inform his company’s succession planning and talent management process.”

Understand employees’ perceptions of the work itself. The person conducting the exit interview understand the departing employee’s job design, working conditions, culture, and peers. By understanding and questioning the employee on this information, the exit interview “can help managers improve employee motivation, efficiency, coordination, and effectiveness.”

Gain insight into managers’ leadership styles and effectiveness. Leadership style is an important reason many employees depart for greener pastures. By inquiring into and understanding this dynamic, an organization can begin to “reinforce positive managers and identify toxic ones. One executive at a major restaurant chain told us that several exit interviews she’d recently conducted revealed that micromanagement was a big problem. The conversations, she said, “led to some very tangible outcomes,”” such as establishing training and development initiatives to create better managers.”

Learn about HR benchmarks (salary, benefits) at competing organizations. While salaries and compensation packages are usually not the driver of departures, they certainly do play a role. You should use the exit interview to do some benchmarking. The authors cited to a HR executive at a global food and beverage who noted, “We use exit interviews to see how competitive we are against other employers: time off, ability to advance, different benefits, and pay packages. And we want to see who is poaching our people.”

Foster innovation by soliciting ideas for improving the organization. The authors believe that exit interviews should go beyond the departing employee’s “immediate experience to cover broader areas, such as company strategy, marketing, operations, systems, competition, and the structure of his or her division.” They cite as one “emerging best practice is to ask every departing employee something along the lines of “Please complete the sentence ‘I don’t know why the company doesn’t just ____.’” This approach may reveal trends which can be incorporated into future innovations.”

Create lifelong advocates for the organization. This is perhaps the most innovative, yet in many ways the most basic, which is of course to treat departing employees with dignity, respect and gratitude. Such treatment at departure may well encourage departing employees to recommend their former companies to potential employees, to use and recommend the companies’ products and services, and to create business alliances between their former and new employers. The authors cite to one North American financial services executive for the following, “You want [a departing employee] to leave as an ambassador and customer.”

Finally are issues around hotlines, whistleblower and retaliation claims. The starting point for layoffs should be whatever your company plan is going forward. The retaliation cases turn on whether actions taken by the company were in retaliation for the hotline or whistleblower report. This means you will need to mine your hotline more closely for those employees who are scheduled or in line to be laid off. If there are such persons who have reported a FCPA, Code of Conduct or other ethical violation, you should move to triage and investigate, if appropriate, the allegation sooner rather than later. This may mean you move up research of an allegation to come to a faster resolution ahead of other claims. It may also mean you put some additional short-term resources on your hotline triage and investigations if you know layoffs are coming.

The reason for these actions are to allow you to demonstrate that any laid off employee was not separated because of a hotline or whistleblower allegation but due to your overall layoff scheme. However, it could be that you may need this person to provide your compliance department additional information, to be a resource to you going forward, or even a witness that you can reasonably anticipate the government may want to interview. If any of these situations exist, if you do not plan for their eventuality before the employee layoff, said (now) ex-employee may not be inclined to cooperate with you going forward. Also if you do demonstrate that you are sincerely interested in a meritorious hotline complaint, it may keep this person from becoming a SEC whistleblower.

Three Key Takeaways

  1. The exit interview is an excellent opportunity to obtain information to inform your compliance program.
  2. Use the exit interview to create advocates from departing employees.
  3. Use the exit interview for probing and insight questions around compliance.

 

This month’s series is sponsored by Advanced Compliance Solutions and its new service offering the “Compliance Alliance” which is a three-step program that will provide you and your team a background into compliance and the FCPA so you can consider how your product or service fits into the needs of a compliance officer. It includes a FCPA and compliance boot camp, sponsorship of a one-month podcast series, and in-person training. Each section builds on the other and provides your customer service and sales teams with the knowledge they need to have intelligent conversations with compliance officers and decision makers. When the program is complete, your teams will be armed with the knowledge they need to sell and service every new client. Interested parties should contact Tom Fox.

With the release of their Evaluation of Corporate Compliance Programs (Evaluation) in February, the Department of Justice (DOJ) emphasized yet again the importance of actually doing compliance and not simply having a paper program in place. The term which has come to the forefront is operationalization of compliance. The Evaluation followed the concepts around best practice compliance programs as articulated in the FCPA Pilot Program Guidance, released in April 2016. Following the Evaluation provides a legal reason for operationalization.

Today, I begin a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am joined in this exploration by Russ Berland, a well-known compliance commentator and practitioner who recently joined Dematic Inc., a Supply Chain optimization company, as it’s CCO. Today I want to articulate the business advantages for operationalization of compliance into a business.

The Evaluation, under Prong 2, asks the following questions, “Shared Commitment – What specific actions have senior leaders and other stakeholders (e.g., business and operational managers, Finance, Procurement, Legal, Human Resources) taken to demonstrate their commitment to compliance, including their remediation efforts? How is information shared among different components of the company?” Under Prong 4, the following questions are found, “Responsibility for Integration – Who has been responsible for integrating policies and procedures? With whom have they consulted (e.g., officers, business segments)? How have they been rolled out (e.g., do compliance personnel assess whether employees understand the policies)?”

Obviously, companies are in business to make a profit. But more than simply making a profit a company desires to continue to do business, preserve its value and, from the compliance perspective, not lose value due to compliance issues; including the failure to prevent, detect, to remediate issues. Yet when these goals are attempted solely by a compliance function, it will not reach its full potential because the compliance reach is not broad enough or deep enough to place it entirely across and through the breadth and scope of a multi-national organization.

Yet these limitations provide the opportunities to do so. More importantly, this same set of limitations also provides a company with a business solution which creates greater efficiencies within an organization. These efficiencies include the effective use of people and resources. It allows those with skills do the work with non-duplication of efforts. More gaps are filled and the converse is also true that fewer gaps are missed. Finally, these efficiencies include the leveraging of local resources and subject matter experts (SME’s) within an organization.

How does a CCO begin to operationalize compliance within an organization? It all begins with breaking down silos, through communications. Berland believes “the biggest obstacle is the same thing that faces us whatever we’re dealing with in corporations. It is if the relationships are not there; if the trust is not there; if the understanding of both what the other person is doing, how you can mutually benefit each other; if those are lacking then the opportunity to create these efficiencies, create effectiveness, create reach, all the things that this kind of cooperation entails, it’s very hard to get past that.” To overcome this lack of trust and structure defect of too many and too deep a silo, Berland noted, “the most effective compliance tool out there is pizza. Because when you are trying to build out these relationships and network … I’ve bought a lot of pizza in my time. It is about sitting down with people, and getting to know them, and building relationships. It’s not some sterile “My box is going to connect to your box,” it’s “This guy is going to get to know this guy and we’re going to make it work.” It’s really about relationships and communication.”

Berland termed many of these concepts as simply “old-school management stuff” yet it is still an effective way to think about operationalizing compliance. Many corporate disciplines have areas which are squarely within their core functions and compliance could utilize their talents and expertise to more effectively inculcate compliance into the fabric of an organization, yet in ways not often considered by a CCO or compliance practitioner.

Consider the role of Human Resources (HR) for anti-retaliation of whistleblowers. Obviously, no corporate function has more touchpoints in the employment lifecycle than HR. Berland related, “HR has a great opportunity is often when there’s a whistleblower involved, and there is some concern that there’s going to be retaliation for the whistleblower. Because, as we know, a lot of investigations into the identity of the whistleblower is either found out or guessed at by people who are being investigated. That HR person is the most likely one to be able to recognize retaliation.”

Through operationalization among the corporate functions, a CCO or compliance practitioner can pursue both the legal requirement for operationalization and the business opportunity to create greater process efficiencies for the company. When you consider this approach, it is the best use of resources within an organization. This can facilitate a compliance interaction by a SME but more importantly allows the person with the decision making and reporting obligation to put compliance at the forefront of the business. Overall, a company can realize business efficiencies because by breaking through typical corporate silos, the organization does not have two or three different departments with the attendant personnel unknowingly doing the same tasks.

When you can wed the cauldron of legal requirements to the brew of increased business efficiencies, you begin to put in place a superior business system. All of this works in your favor if your company becomes embroiled in a Foreign Corrupt Practices Act (FCPA) investigation. By demonstrating more integration of compliance into the business of your company, you can demonstrate to the government your commitment to and actual operationalized compliance program. When a solution has both business and legal benefits it works for the greater good across a wider variety of spectra.

Tomorrow I consider some of the obstacles you may face when operationalizing your compliance program and what steps you might consider to overcome them.

 

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2017