Essential elements of a Corporate Compliance programme

Source: Presented at C5’s 2nd Forum on Anti-Corruption, West Africa. Full presentation available here.

Essential elements of a Corporate Compliance programme

Organisational leadership & culture •Tone from the Top •Compliance and Controls structure (FTE and non-FTEs) •Incorporating compliance objs into coy-wide objs Standards & Procedures •Internal policies, procedures and SOPs Training & Communications •Mandatory trainings •Trainings deep diving into high risk areas •Innovative communications e.g. Internal newsletters, weekly tips, branded items Enforcement & Incentives •Robust consequence mgmt protocols •Incentives (internal and external) e.g. Awards, acknowled-gements, endorsements Due care in delegating authority •3rd Party due diligence •Extending mandatory trainings to key 3rd parties •Annual compliance certification for key 3rd parties Monitoring, auditing & reporting •Enhanced whistleblower reporting platforms •Backend and front-end monitoring/compliance reviews •Robust breach management processes Response & continuous improvement •Feedback employee compliance surveys •Annual certifications (internal & external) Organisations whether, public or private, should strive towards moving from awareness to repetoire/embedding these pillars in their Compliance programme.