If you have children, you have probably experienced a moment of horror when you realize you have not adequately prepared your child for the danger zone that is your home. Despite all your best efforts to “childproof” your house, hands will touch hot stoves, little fingers will go into sockets, and you no doubt will grow a few gray hairs.
Compliance officers are not that different from parents. While you cross your fingers and hope that the compliance program you have put in place is robust enough, you no doubt will also experience a moment when you realize your employees might not be fully aware of policies and procedures, or might not know what to do when they come across something suspicious putting not only themselves, but the entire company at risk.
In corporate America, there are companies that are either going through or will go through a compliance investigation if they are not proactively updating their program. Just look at the record number of SEC investigations. In FY 2012, the SEC filed 734 enforcement actions, just one less than the previous year. So how do you make sure you aren’t one of those companies–and if you are, what then? Ethics specialist Frank Bucaro, in a recent post on the SCCE’s LinkedIn group, astutely puts it this way: “Being proactive is high road behavior, builds loyalty, fosters positive morale, and can have significant impact on decreasing the odds of a costly lawsuit.”
The best defense against SEC and DOJ investigations is staying ahead of the curve. Choose a natively integrated GRC program to stay abreast of any risky behavior. With an integrated GRC program all of your compliance information feeds into one central repository– cross reference training certifications with reports of non-compliance to pinpoint and solve problem areas. Don’t take silence and a lack of compliance cases as a cue that your company is above risk. If you haven’t experienced any hiccups in your compliance program, you still need to be proactive in examining the effectiveness of your initiatives. Here’s a startling statistic: Nearly one in every one hundred employees observes an act of bribery or corruption (CFO Executive Board).