What is a page of compliance worth?

Justice Oliver Wendell Holmes famously said that a page of history can be worth a volume of logic.  This raises the question – at least among C&E professionals – What is a page of compliance worth?

At least to my mind the answer is:  Potentially quite a bit.

Among other things, some companies draft and disseminate among their respective workforces “one pagers” summarizing key provisions of the compliance program with respect to certain high-risk areas –  as well as contact information for seeking guidance or reporting concerns.

I should stress that not all companies need this.  For many it would be overkill.  But for others it could be very helpful.

The conflicts of interest “one-pager” would of course focus on COI policies and procedures. This would include apparent, as well as actual COIs.  For some companies potential COIs. should be addressed too.

There should also be some discussion of the behavioral ethics aspect of COIs – and particularly the seeming paradoxical fact that disclosure may make conflicted behavior more common than one would expect. Although based on COIs this behavioral ethics learning supports the compliance program as a whole by showing we are not as ethical as we think.

Finally, there should also be a discussion of the harm that COIs can have on shareholders, employees and suppliers. This is important because – more so than with many other types of offenses – COIs often give the mistaken  impression of being victimless.

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