A culture, not a programme

Author: | Published: 1 Dec 2009

Compliance breaches are costly, time consuming, a distraction and embarrassing. In many cases, it can result in the implosion of the company itself. Witness the Enron scandal, and more recently, the case of Satyam. Both were companies ironically hailed for their compliance programmemes and infrastructure but had ethical issues at their core.

As a result, companies are seeking quick solutions by implementing compliance programmes. Much has been written about what constitutes an effective compliance programme. Many of these naturally hinge on what your respective regulators consider to be necessary elements of a compliance programme (see for example the Bureau of Industry and Security's Principles of Effective Compliance Programmes and the Australian Competition and Consumer Commission's thoughts): a documented risk analysis, a compliance manual or code of conduct, the existence of a structured compliance organisation and so forth.

Another popular source of guidance comes from Chapter 8 of the US Sentencing...