Assessing compliance and ethics programs
This week, at the PLI Compliance & Ethics Institute, I gave a presentation on assessing C&E programs. In my talk – the slides for which are here – I address legal imperatives for program assessments; the difference between program assessments, audits and risk assessments; the issue of who should conduct the assessments; the various assessment criteria that one can use – both in terms of program elements (e.g., training, monitoring) and program “attributes,” which are characteristics of successful programs (e.g., the “reach” of a program) that “cut across” program elements. I also discuss deep (and less-than-deep) dives into both risk areas (e.g., anti-corruption, competition law and conflicts of interest) or program elements (e.g., investigations or board oversight).
I hope you find this interesting.