tailoring the training to the circumstances, treating the training as an after-thought, maintaining the relevance of the training to employees’ jobs, and ensuring the training is engaging. Also, the organization offers additional specialized training to workers whose job functions expose them to risks and the members of the board and the senior management. This organization is committed to promoting dialogue between the employees and the high-ranking officials through multiple channels. The supervisors maintain a free environment thus promoting open communication. The organization disseminates information appropriate to respective roles and responsibilities of an individual (Wulf, 2012). The organization raises awareness of the ethics and compliance program among the
AN ETHICS AND COMPLIANCE PROGRAM 8 employees. The steps the company has taken to increase awareness of the program include; speeches, posters, e-mails, tent cards placed on the tables of the cafeteria, and the wallet cards. The organization’s primary goal of creating an open line of communication is to ensure that the employees are aware of where to report to issues for example, in the case of abuse and fraud, a potential violation of regulations, law, or company policies (Wulf, 2012). The workers submit reports to their management, human resource, ethics and compliance department, or to the chief ethics and compliance officer. This organization has established a hotline available to the workforce 24 hours throughout the week throughout which they report potential violations of policies and legal obligations. The organization maintains anonymity. The sentencing guidelines outline that an organization is to ensure that the board of directors, senior management, and the employees follow the ethics and compliance program, including auditing and monitoring to detect misconduct. A company is to evaluate the effectiveness of its ethics and compliance program periodically. Auditing is checking of the program after completion, and monitoring is checking the program time to time. Both auditing and monitoring are essential for an effective ethics and compliance program (United States Sentencing Commission, 2005). This organization provides its auditing and monitoring of its compliance activities through conducting a yearly risk assessment and coming up with a compliance work plan. The audit procedures target a violation likely to occur. The company has taken various steps to ensure that the compliance procedures are functioning in line with the plan. The auditing and monitoring of the program include whether all employees have the code of conduct, scheduled training has occurred, disciplinary process is functioning as intended, and means for improving the program are pursued.
AN ETHICS AND COMPLIANCE PROGRAM 9 Izraeli & Schwartz (1998), the nature, extent, and the frequency of auditing and monitoring depend on various factors such as changes in the business practices, new regulatory requirement, and other considerations.
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