When assessing your ethics and compliance program, it seems only natural to look at each individual plank on its own, but as compliance expert and attorney Michael Volkov explains, this approach could fail to surface issues with program elements that don’t work in concert with one another.
We often hear about the “essential” elements of effective ethics and compliance programs. It is natural for professionals to define specific elements of an ethics and compliance framework, and this is an important way to break down a program for assessment purposes.
While analyzing the specific functions in a program, we must avoid a narrow review of each element. Instead, as in most issues, the analysis of each element has to incorporate a factor that captures the interdependency of various elements. For example, the effectiveness of one element may enhance or improve the operation of another element. A simplistic way to express this idea is that the whole is often larger than the sum of the parts.
An example of this is the interdependency of employee reporting systems, investigations and specific training programs. Let’s start with the reporting system. There is no question that a company’s compliance program operates more effectively when the company maintains an efficient and trusted mechanism to report…
