Joe Murphy (firstname.lastname@example.org) is a Senior Advisor at Compliance Strategists, SCCE’s Director of Public Policy, and Editor-in-Chief of CEP Magazine.
Recently the Canadian Competition Bureau’s director of compliance, speaking at an American Bar Association virtual program, offered some interesting insight about approaches to compliance programs.
One that I found particularly important was this: When it comes to assessing compliance programs, they look at information gathered during the substantive investigation. In effect, what they see and hear from employees and those who deal with the company is relevant to their determinations about the compliance program. The bureau definitely takes compliance programs into account for enforcement decisions, so this is an essential point.