Tagged: policies and procedures

Spring Cleaning: Time to Review Your Internal Controls

There are a lot of so-called “dirty secrets” in the corporate governance world.  Not the tawdry kind that appear to follow controversial politicians – I mean in the world of internal controls. I would wager that most companies cannot even identify all of the policies, procedures and controls that have been created during the life of the company.  Some exist in what I call the...

The Perfect Compliance Combo: Culture and Controls

Compliance practitioners divide their commentary and insights into two general categories – ethical culture and compliance controls. It is easy to divide compliance issues into these two categories. Ethical culture articles are a little less concrete; compliance controls are practical and focused on policies and procedures. A compliance program cannot be deemed effective, however, unless there is a combination of these two important functions. An...

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does not violate the law. A much simpler way to put it is – a company’s due diligence system is designed to negate any inference of intent to violate the FCPA.   A due diligence...