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Advanced Compliance Strategies

Advanced Compliance Strategies. Taking the Existing Compliance Program to Another Level. Gary F. Giampetruzzi Pfizer Corporate Compliance November 14, 2003 Washington, D.C. Seven Standard Elements of the Effective Compliance Program. Written standards and procedures

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Advanced Compliance Strategies

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  1. Advanced Compliance Strategies Taking the Existing Compliance Program to Another Level Gary F. Giampetruzzi Pfizer Corporate Compliance November 14, 2003 Washington, D.C.

  2. Seven Standard Elements of the Effective Compliance Program • Written standards and procedures • Responsibility for Oversight of Compliance • Effective Communications and Training • Auditing / Monitoring and Employee Reporting Systems • Undertake Reasonable Steps to Respond Appropriately • Employ Appropriate Disciplinary Mechanisms • Exercise Due Care in the Delegation of Discretionary Authority Footer goes here

  3. COMPANY A (before) Code of Conduct Been around for years Written by lawyers, for lawyers Some Level of Distribution / Certification Most generally receive it Some, but not all make certification Some Level of Promotion Some, but not all know about it No Other Avenues of Colleague Access COMPANY A (advanced) Enhanced Code of Conduct New, fresh engaging look and feel Written for the average colleague Greater Scope of Distribution / Certification All receive it Most, if not all, certifications electronic Greater Promotion Articles, posters, giveaways, etc. Code of Conduct Web-site FAQs, scenarios, etc. Full text of underlying policies available Rules and Standards – Advanced Approaches Footer goes here

  4. COMPANY A (before) Corporate Compliance Officer Corporate Compliance Officer Decentralized support structure Corporate Compliance Committee ??? Other Compliance Group Support Many groups involved, but decentralized CEO / CFO / Board Involvement ??? COMPANY A (advanced) Corporate Compliance Officer Corporate Compliance Officer Deputy Corporate Compliance Officer Regional / Site Compliance Liaisons Corporate Compliance Committee Two-tiered system One higher-level, workable group One broader group; all compliance Other Compliance Group Support More centralized, close relationships CEO / CFO / Board Involvement Regular updates, copies of matters reports Corporate Oversight – Advanced Approaches Footer goes here

  5. COMPANY A (before) Ad Hoc Communications Decentralized, sporadic communications Reaches some, but not all Ad Hoc Training Decentralized, sporadic training efforts Reaches some, but not all No Advanced Strategies COMPANY A (advanced) Comprehensive Communications Program Centralized plan, consistent message Designed to reach all colleagues Comprehensive Training Program More centralized, consistent training efforts Cross-functional, business, legal, etc. Designed to reach all colleagues Worldwide Web-Based Training Program Standardized content, saves resources Training based on specific responsibilities Fills existing gaps, comprehensive coverage Best possible record of compliance efforts Communications and Training – Advanced Approaches Footer goes here

  6. COMPANY A (before) Open Door Policy Colleagues allowed to step forward A written policy, without much more Compliance Hotline An existing system, without much more Auditing and Monitoring Functions Doing the job, but not coordinated No Measurement of the Systems COMPANY A (advanced) Open Door Policy Articles, posters, giveaways, etc. Formal guidelines and procedures Not just communication, but training What to report? . . . RCIs Compliance Hotline Articles, posters, giveaways, etc. Auditing and Monitoring Functions Work w/ centralized compliance function Measure the Systems Employee feedback, statistical analyses Auditing / Monitoring and Reporting – Advanced Approaches Footer goes here

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