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    6 steps to ensure a powerful Compliance and Ethics Strategy

    Published on 03 Aug 2017 by Lynne Callister

    It's important to stay on top of your firm's risk management and lay a strong foundation for your Compliance and Ethics strategy.

    A 2016 State of Compliance Study by PwC shows:

    • 98% of senior leaders say they're committed to compliance and ethics
    • 67% have a process in place to identify the owners of compliance and ethics-related risks
    • A third have an officer in overall charge of compliance and ethics
    • 56% of companies don't have a chief ethics officer
    • 20% have Board of Directors that formed separate compliance and ethics committees
    • 82% of leaders communicated with employees on ethics, but 46% of this is done in business meetings or by email

    Top tips to boost your compliance and ethics strategy:

    1. Set policies, controls and procedures - Decide what's important and how you're going to achieve it.
    2. Arrange effective compliance oversight - Get the "tone from the top" right, and appoint someone with overall responsibility for compliance/ethics. This increases accountability and ensures things get done.
    3. Conduct due diligence - Conduct adequate due diligence on all business partners, including associates and third parties. Make sure you're not delegating authority to those who are unfit or unsuitable.
    4. Provide information and training - Make sure everyone understands your compliance programme, rules and expectations. Be careful how you do this too - put your compliance and ethics messages front and centre, rather than a 5-minute add-on at the end of business meeting.
    5. Monitor and audit behaviour and your overall C&E programme -  Ask yourself - Is it achieving the desired results? How do you know? (Data should be collected so monitoring is objective.) Is it effective? Are the rules or policies doing as expected? Can anything be improved? If so, how?
    6. Use enforcement to deal with violations - Make sure that rules are applied consistently and you respond to all breaches effectively. Publicise cases (while balancing the need for confidentiality) so offenders are clearly seen to face sanctions for violations. Use information about violations to improve your C&E programme for the future.

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