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Making the shift to principles-based compliance programs

Tosin Umukoro ( is the Senior Compliance Officer for Stryker Europe.

Over the years, corporate compliance programs have developed helpful frameworks of dos and don’ts for people in worst-case scenarios. Although generally considered effective in addressing significant and known risks faced by organizations, these programs, typically heavily rules-based, have been criticized for creating a series of box-checking routines, or so-called “paper programs,” primarily aimed at assuring legislators of the adequacy of self-policing and internal policies and procedures.

To create a culture of integrity, given the complex requirements governing business today, organizations need to continually evolve to address new and emerging risks and embrace both reactive and proactive approaches to compliance. In recent years, principles-based compliance programs have grown in prominence due to their potential to empower people to make the right ethical decisions, particularly in difficult or unique situations. This article presents some considerations for compliance professionals seeking to implement this approach to improve the effectiveness of their compliance programs.

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