It is essential that compliance programs engage their organization’s senior leaders. This is not only an expectation from a regulatory perspective but also critical to fostering compliance program effectiveness.

Engaging operations in compliance is vital to ensuring compliance. The March column discussed the importance of senior leadership compliance engagement.^[1] Senior leaders drive operational compliance, setting the expectation for compliant functions. While senior leaders should “clearly articulat[e] the company’s ethical standards, conve[y] and disseminat[e] them in clear and unambiguous terms, and demonstrat[e] rigorous adherence by example,” managers—those who supervise departments and teams—work to implement these goals, “reinforc[ing] those standards and encourage[ing] employees to abide by them.”^[2] This management compliance responsibility includes ensuring employees have the necessary resources to perform their jobs compliantly (i.e., policies and procedures, appropriate training), monitoring high-risk functions, promoting a culture of transparency and encouraging reporting, and being part of corrective action plans and remediation of risk where identified.