The key to Compliance Risk Management is to train employees to independently recognize and efficiently resolve compliance problems.
Compliance programs entail monitoring of employees’ behavior with the objective of preventing corporate criminal liability. This protects businesses from lengthy litigation and costly sanctions.
Moreover, even if a Compliance Program fails to deter unlawful conduct, it may allow the company to uncover and remedy it before regulators.
Our Approach to Compliance Risk Management
At UBR Compliance, we believe the basis of an effective compliance program lies in the employee being able to answer the following questions.
(1) What did you do to prevent it?
(2) What did you find when you looked into it?
(3) What did you do when you found out about it?
In our experience, a firm engaged in unlawful behavior is likely to receive a reduced sanction if a Compliance program was in place at the time of the infringement.
However, for any Compliance Program to be effective, the company must train their employees on what they are to do; where they can go and how to escalate the problem.
From the above, Our approach to Compliance Risk Management includes:
(i) Educating employees about risky activities,
(ii) Monitoring employees’ behavior,
(iii) Disciplining employees in case of illegal conduct.
At UBR Compliance, our key strategy is to equip and train your employees. This helps them independently recognize when a compliance problem has arisen. We also create systems to quickly and efficiently resolve the problem.
In our experience, it is best commence your compliance program by designing a written Code of Conduct. This clearly articulates what behaviour is expected from employees and management.
We build upon the Code of Conduct by crafting a clear policy statement in simple language. The compliance policy needs to written in plain English or at least in language that a business person can understand.
We also include a detailed statement of the compliance procedures. This explains the process by which your company will efficiently manage the compliance risk. This message must be reinforced by emails, posters, reminders by management and any other form of media.
Internal controls can potentially deteriorate over time. Compliance Monitoring is important in order to evaluate the effectiveness of the compliance Program.
Monitoring should be performed on a regular basis and the results submitted to senior management to ensure prompt action to correct any deficiencies or breaches identified.
The objectives of the monitoring review are to identify any deficiencies in control procedures; and evaluate the likelihood of the failure of any control procedures.
The effective monitoring of controls can lead to the timely identification and correction of internal control problems.
We monitor and test compliance against the relevant laws, regulations, codes of practice and internal policies or procedures. Over time, the effective monitoring of internal controls should also lead to increased organisational efficiencies.
Discipline is an important part of a compliance program, but arises in two slightly different situations:
First, is the notion, that a compliance program should include incentives for employees to follow the program, along with punishment or discipline for failing to follow the program.
Second is the concept that a company should have a rational program of employee discipline for various policy violations. But more than just being seen as an attribute of compliance, consistent discipline is also an attribute of good management practices in general.
If discipline is warranted, UBR Compliance supports your organisation in its timely, fair and efficient administration.
In developing and maintaining effective ethics and compliance programs, our clients strengthen and protect their companies.