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Key considerations for your program's self-assessment

Danielle Herrick (dherrick@employers.com) is Vice President, Corporate Compliance Officer for EMPLOYERS in Reno, Nevada, USA.

The phrase “effective compliance and ethics program” is widely used and frequently discussed. Determining whether your program is effective, however, requires more than a superficial understanding of the U.S. Federal Sentencing Guidelines[1] and Department of Justice guidance.[2] It requires a specialized knowledge of the laws and regulations that apply to your organization, the compliance and ethics risks for your organization, and knowing which controls you should have in place to mitigate them. Conducting a self-assessment is your first step.

A compliance and ethics program self-assessment is for mature programs with leaders who are willing to take a critical look at what’s working and what needs improvement. It is not for the faint of heart or for a compliance program in its infancy; however, the concepts detailed here can also be used to set goals and objectives when developing or advancing a young program.

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