How SOEs carry out effective compliance management evaluation

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The effectiveness evaluation of compliance management systems in state-owned enterprises (SOEs) urges them to fulfil compliance obligations and to inspect and judge the actual utility of identifying, analysing and preventing compliance risks.

The Central SOEs Compliance Management Measures, which took effect in late 2022, strengthened requirements for the effectiveness evaluation of compliance management, becoming the highest-ranked normative document in the field of SOE compliance management system construction.

Current shortcomings

Liang ZhengLiang Zheng
Liang Zheng
Partner
AllBright Law Offices

Single evaluation standard
The current effectiveness evaluation of SOEs’ compliance management focuses more on meeting standards, typically using a vertical compliance structure for assessment. The evaluation indicators are relatively principled. Except for the Securities Companies Compliance Management Effectiveness Evaluation Guide, issued by the China Securities Regulatory Commission, no documents describe standards, methods and evaluation indicators.

Insufficient depth of review
Related work is usually based on onsite written reviews. Experts spend short times on onsite reviews, and evaluators often have…

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