I often receive emails and calls about the compliance service offerings which I can assist companies with through my consulting company Advanced Compliance Solutions. Based on this, I am dedicating this week to some of the offerings I have in place and with which I can assist the Chief Compliance Officer (CCO), compliance professional and corporate compliance program. My latest offering is one based upon the recent eBook I authored with Jonathan Marks at Baker Tilley Virchow Krause, LLP, the Compliance Program Game Plan. I am offering this service jointly with Marks so you will be getting two of the top compliance practitioners around.
In this service offering, we provide a guide for CCOs and those responsible for developing and implementing compliance policies and procedures for an organization. It will facilitate your corporate compliance program having a best-in-class compliance program going forward. We break down our approach into four easily digestible components: (1) the first 90 days, (2) the first 90 days, (3) the first 180 days and (4) the first 18 months.
First 30 Days
In the first 30 days, we will help you (a) Review the compliance budget, (b) Meet with leaders from other corporate functions, (c) Review internal documentation and (d) Inventory compliance policies and procedures. The role of the compliance policies is to prevent, detect and remediate any compliance or related issue(s) which may arise with the organization, employees and third parties working on behalf of the company. A company’s compliance policies provide a basic set of guidelines for employees and others to follow. Compliance policies should provide general prescriptions and be supplemented by more specific procedures. By establishing what is and what is not acceptable, ethical and compliant behavior, a company helps mitigate the risks posed by employees who might not always make the right ethical choices. The key in this first phase is to obtain a full grasp on the basic state of your compliance program and meet with key stakeholders.
First 90 Days
In the first 90 days, we will assist you in continuing a review of key documents and then move out onto the road with you. We can assist with some or all of the following: (a) A worldwide listening tour to engage and educate throughout the organization, (b) Review past data and findings in all risk assessments, hotline reporting data, internal audits, culture surveys, internal investigations or other documents that discuss the state of your compliance program, (c) begin the process to refine or develop training and delivery, (d) improve communications from the compliance function to and through the organization and (e) meet with our outside compliance counsel, both those you utilize for investigations and those who focus more on the nuts and bolts work of compliance. We recommend you undertake a minimum two-week Listening Tour, to engage employees with the compliance function and to educate the workforce on the goals and objectives of the program. This listening tour should reach across the world of the company – both geographically and functionally. The goal of the listening tour is to both engage and educate employees.
First 180 Days
In this phase, we will assist you in beginning to actively move forward. We will assist you to (a) Perform a gap analysis of the internal compliance controls. (b) bring in an outside independent to administer a cultural survey, (c) work with your Chief Financial Officer (CFO) and their team to review and analyze key financial processes to understand how compliance fits into that framework and (d) hold a Compliance Retreat. A gap analysis is mainly a document review or a “show me the proof” type activity, evidence which usually will come in the form of a record or document. During a gap analysis, there is some auditing accomplished, with key stakeholders providing the evidence they may have – or not – for each of the requirements set forth in the relevant internal controls standard. Conversely, by bringing two of the top outside compliance consultants, your company will be able to obtain a broader picture of where its culture exists as, more usually than not, employees are more willing to open up to an independent outsider, rather than someone in their own organization.
In the first 365 days, we will assist you to engage in the following steps: (a) create a Compliance Center of Excellence (CCOE) and (b) provide training and coaching for your compliance team so that they can lead with the message of doing business ethically and in compliance. The development of a CCOE would allow compliance to be more integrated into overall strategic planning and allow for strategy discussions to stay tuned to the ever-changing risk profile of a company. Moreover, through an interdisciplinary approach, it would bring compliance knowhow to help the employees and executives understand that compliance is, in reality, a business process that can easily be incorporated into business unit operating procedures going forward. Finally, we are then available for retention as outside consultants who can work with the CCO and each team member to set up a personalized training and coaching program to help fine tune their individual compliance expertise. While it would have a leadership training component, this program is not designed to focus on leadership development but on compliance development.
The great thing about the Game Plan is that is can slot in wherever you might be in your own compliance program journey. If you would like more information, give myself or Jonathan Marks a shout.