International Compliance 101

  1. Copyright

    International Compliance 101, 2nd Edition  | August 2018 

    Copyright © 2013-2018 by the Society of Corporate Compliance & Ethics...

  2. Introduction: The Name of the Game

    International Compliance 101, 2nd Edition  | August 2018 

    The adoption of compliance and ethics programs continues to grow as more industries and more regions of the world embrace its underlying principles. In 2018, the Society of Corporate Compliance and Ethics (SCCE) includes members from 98 countries...

  3. Chapter 1: What Is a Compliance Program

    International Compliance 101, 2nd Edition  | August 2018 

    Compliance is often defined in dictionaries as, “The action or fact of complying with a wish or command or a set of rules.” This can be a set of external rules, such as laws, regulations or third party contractual obligations or it can be a set of internal rules, such as codes of conduct and internal policies or controls, which are imposed by the organization itself...

  4. Chapter 2: The Seven Essential Elements

    International Compliance 101, 2nd Edition  | August 2018 

    The first of the basic compliance elements in industry guidance recommends that the organization establish standards and procedures to prevent and detect criminal conduct. The standards or code of conduct and the policies and procedures help to create the infrastructure for your compliance program...

  5. Chapter 3: Organizational Steps

    International Compliance 101, 2nd Edition  | August 2018 

    Effective compliance programs require oversight from the governing board. Support from the top is very important; there can be no program at all, much less an effective one, without the vision and guidance of the board. It is the board that officially recognizes the need for a compliance program and authorizes its launch and implementation, including the recruitment and retention of a compliance officer. An organization with an effective compliance program will have a culture of accountability and a demonstrated commitment from management through its communication to the organization. Depending on the organization, a resolution or memo from the board...

  6. Chapter 4: Tailoring Your Compliance Program

    International Compliance 101, 2nd Edition  | August 2018 

    The compliance program must be tailored to fit your organization. There is not a “one size fits all” program. As we have discussed, you need commitment from the top actively supporting your program, financial support including necessary staffing, and a continual assessment of your program. Once you understand the organization’s needs, then you can fit your plan to the organization. The code of conduct should be the focal point of your program...

  7. Epilogue

    International Compliance 101, 2nd Edition  | August 2018 

    As you know, better than most, compliance professionals must deal with complex and cumbersome laws and regulations daily. But industry laws and regulations are not new. Today, more so than in the past, we are approaching compliance in a formal, systematic way. Armed with a mandate from regulatory agencies, our board and senior leadership, we are creating and implementing compliance programs—programs that embody and fulfill our organizations’ commitment to compliance as part of providing the best possible services...

  8. Appendix A.1: Sample Letter to Vendors

    International Compliance 101, 2nd Edition  | August 2018 

    Dear Vendor Colleague:...

  9. Appendix A.2: Sample Compliance Officer Job Description

    International Compliance 101, 2nd Edition  | August 2018 

    The compliance officer provides direction and oversight of the compliance program. The compliance officer is responsible for identifying and assessing areas of compliance risk; communicating the importance of the compliance program to the executive management and the board of directors; preparing and distributing the written code of conduct setting forth the ethical principles and policies which are the basis of the compliance program; developing and implementing education programs addressing compliance and the code of conduct; implementing a retaliation-free internal reporting process, including an anonymous telephone reporting system; and collaborating with executive management to effectively incorporate the compliance program within system...

  10. Appendix A.3: Sample Audit Review Form

    International Compliance 101, 2nd Edition  | August 2018 

  11. Appendix A.4: Audit Review Plan Templates

    International Compliance 101, 2nd Edition  | August 2018 

    * Audit required by XX regulatory, accreditation or other agency...

  12. Appendix A.5: Sample Non-Retaliation/Non-Retribution Policy

    International Compliance 101, 2nd Edition  | August 2018 

    XXX has implemented a compliance program that promotes the highest standard of ethical and legal conduct. Standards of conduct and procedures for faculty members, residents, and staff are implemented to guide this effort...

  13. Appendix A.6: Sample Confidentiality Statement

    International Compliance 101, 2nd Edition  | August 2018 

    I understand and agree that, in connection with the performance of my duties as a member of the compliance oversight committee, I will be engaged in activities of a confidential nature, including but not limited to, participating in reviews and evaluations of internal examinations, evaluations, and self-evaluations of the policies, practices, and procedures of this organization. I further understand that, in this capacity, I will be expected to receive and/or to become privy to information of a confidential nature, including but not limited to, financial statements, trade-secrets, strategic plans, contracts with private parties, and other documents and statistics which go...

  14. Appendix A.7: Sample Complaint Information Sheet

    International Compliance 101, 2nd Edition  | August 2018 

    * How to make call # assignment: The month plus initials of the person taking the call plus the # of call. Log knowledge-based concerns or questions, i.e., billing, policies, education, financial statements, contracts, et cetera (for example: 08 DT 001)...

  15. Appendix A.8: Sample Compliance Issue Follow-Up Form

    International Compliance 101, 2nd Edition  | August 2018 

    (Optional: Can be used with the “Sample Complaint Information Sheet—Questions and Concerns Call Log Sheet”)...

  16. Appendix A.9: Sample Search Warrant Response Policy

    International Compliance 101, 2nd Edition  | August 2018 

    (might not apply in some countries)...

  17. Appendix A.10: Sample Board of Directors Resolution

    International Compliance 101, 2nd Edition  | August 2018 

    Office of the Secretary and Chief of Staff To Members of the Committee on Compliance and Audit:...

  18. Appendix A.11: Sample Budget Areas for Compliance

    International Compliance 101, 2nd Edition  | August 2018 

  19. Appendix B: Code of Ethics for Compliance and Ethics Professionals

    International Compliance 101, 2nd Edition  | August 2018 

    Compliance and ethics programs serve a critical role in helping to prevent and detect misconduct at and by organizations and to promote ethical business environments. The development and rigorous implementation of effective compliance and ethics programs protects investors, consumers, the business community and the public at large. Compliance and ethics professionals (CEPs) understand that the services we provide require the highest standards of professionalism, integrity and competence. The following Code of Ethics expresses the profession’s recognition of its responsibilities to the general public, to employers and clients, and to the profession. The Code of Ethics has been adopted by the...

  20. Glossary of Compliance Terms

    International Compliance 101, 2nd Edition  | August 2018 

    APEC — Asian-Pacific Economic Cooperation is an intergovernmental group formed to facilitate economic growth, cooperation, trade and investment in the Asia-Pacific region. It operates on the basis of non-binding commitments, open dialogue and equal respect for the views of all participants...

  21. About the Authors

    International Compliance 101, 2nd Edition  | August 2018 

    Debbie Troklus, CHC-F, CCEP-F, CHRC, CHPC, CCEP-I, is a Senior Managing Director for Ankura Consulting, where she advises clients on a wide variety of compliance related topics including compliance program implementation, compliance program effectiveness reviews, coding and billing, audit, education development and delivery, investigations, IRO services and interim and/or outsourced compliance work. She currently serves on the board of the Society of Corporate Compliance and Ethics & Health Care Compliance Association and is a past President of this association. She also serves as the current president for the Compliance Certification Board...