7 Elements Roundtable

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1 7 Elements Roundtable Listen. Learn. Share. Connect Rules Participants break into 7 groups Introductions Get acquainted; build your network Each groups should delegate secretary (notes) & a speaker to share the group s ideas Groups will have mins. to discuss best practices Group speakers share best practices with full group

2 Element 1 Establish Standards and Procedures To communicate organizational values and expectations regarding employee behavior To explain the operation of the Compliance and Ethics Program To clarify and establish internal standards for compliance with laws and regulations To help employees understand consequences of non-compliance to both the organizational and individual employee What are some best practices in establishing standards and procedures to prevent and detect violations of laws and regulations? What some best practices in developing and implementing a new or revised Code of Conduct

3 Element 2 Exercise Effective Oversight To demonstrate internally and externally the organization s commitment to integrity To establish an individual with appropriate authority to serve as the focal point for ethics and compliance activities To ensure training, risk assessment, oversight, and monitoring of company-wide compliance To support executive leaders in the prevention of misconduct and compliance failures and effectively address issues if they occur Who is accountable for the oversight of a company s compliance & ethics program? Who is responsible for day-to-day management of a company s C&E program? What type of information about the C&E program is reported to the company s governing authority and how often?

4 Element 3 Training and Communication To promote the understanding of and compliance with relevant federal, state and local laws and regulations To enable implementation of the compliance program s policies and procedures and to ensure that employees understand their role in the compliance process To demonstrate the organization s commitment to compliance and to ensure that commitment is reflected throughout the organization What are some best practices for compliance communications and awareness campaigns? What are some best practices in developing and delivering compliance training? Does your governing authority receive training on their oversight responsibilities?

5 Element 4 Auditing and Monitoring To identify possible misconduct or criminal activity To identify areas where compliance standards have not been fully understood or fully implemented To test the completion and effectiveness of compliance training To measure and benchmark the effectiveness of the organization s compliance program To be more effective at identifying risk areas on which to concentrate performance improvement efforts What are some best C&E monitoring and auditing practices? What are some best practices for periodically evaluating the effectiveness of a C&E program? How can an organization best assess compliance risk?

6 Element 5 Reporting To encourage the prevention of violations To create an environment where open communication is encouraged To achieve an open environment where employees believe that their good faith report will be addressed What are some best practices for creating an open work environment? How can a workplace best provide employees with methods to report problems or raise concerns? What are the most useful Hotline metrics?

7 Element 6 Incentives and Enforcement To reinforce and provide positive feedback for ethical conduct To earn and maintain public trust through the organization s commitment To enforce the message that investigations will be fair, and misconduct will be punished To show that the organization has taken reasonable steps to prevent or detect criminal conduct What are some best practices to incentivize employees to perform in accordance with the program? What are some best practices for appropriate discipline when an employee violates Code of Conduct expectations?

8 Element 7 Response and Prevention To maintain an organization s reputation as reliable, honest and trustworthy To preserve the legal status of the organization To document corrective and preventive actions that demonstrate the compliance program is effective What are some best practices to respond to and investigate incidents/ reports of concerns? What are some steps to take to prevent further incidents from recurring? How would you measure effectiveness?