Effective Compliance is More Than the Sum of a Program’s Parts

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Why Your E&C Program Should Be Operationalized

An ethics and compliance program is in trouble from the start if it meets with staunch opposition from any element within in the organization. Michael Volkov explains why the best programs are operationalized, with buy-in and cooperation from every function.

The beauty of an effective ethics and compliance program is captured in the well-known phrase – it is worth much more than the sum of its parts.

I am reminded of the Beatles refrain, “All Together Now,” which is an apt reminder of the importance of operationalizing an ethics and compliance program. Frankly, the life of an ethics and compliance program depends on the extent to which it is operationalized.

A compliance program lives or dies depending on the cooperation and coordination of every element of a corporation, starting with the C-Suite and stretching from the business to human resources, finance, security, internal audit, procurement and on and on. Together, each of these disparate functions has a contribution to make and an important role to play in the overall operation of the compliance program.

When one player fails to participate or resists cooperation, the compliance program is unlikely to succeed, since each function houses important aspects of a compliance…

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