Chapter 1: Overview of Compliance and Ethics Practice
The Role of Ethics, Compliance, and Culture in Reducing Risk of Misconduct
The Compliance and Ethics Profession: SCCE’s Code of Professional Ethics for Compliance and Ethics Professionals
Code of Professional Ethics for Compliance and Ethics Professionals
Chapter 2: Foundational Materials and Program Infrastructure
Essential Elements of an Effective Ethics and Compliance Program
APPENDIX 2-A: Sample Letter to Vendors
APPENDIX 2-B: Sample Nonretaliation/Nonretribution Policy
APPENDIX 2-C: Sample Compliance Officer Job Description
APPENDIX 2-D: Sample Audit Review Form
APPENDIX 2-E: Sample Confidentiality Statement
APPENDIX 2-F: Sample Hotline Information Sheet
APPENDIX 2-G: Sample Compliance Issue Follow-Up Form
APPENDIX 2-H: Glossary of Compliance-Related Terms
The History of the Organizational Sentencing Guidelines and the Emergence of Effective Compliance and Ethics Programs
Beyond the Sentencing Guidelines: Governing Directives, Guidelines, and Standards from the United States
Components of an Effective Compliance and Ethics Program
Chapter 3: Implementing a Program
Getting Started
Initial Steps for Building a Compliance and Ethics Program
APPENDIX 3-A: Compliance Program Implementation Action Plan
APPENDIX 3-B: Compliance Job Description
APPENDIX 3-C: Compliance Program Risk Inventory
APPENDIX 3-D: Sample Compliance Committee Charters
APPENDIX 3-E: Sample Policies and Procedures
Making the Business Case: Selling Compliance and Ethics to Management
Appendix 3-F: Benefits of a Compliance Program
Compliance Standards and Procedures
Creating a Code of Conduct
Communicating Values Across Cultures: Globalizing Your Code of Ethics
APPENDIX 3-G: General Checklist for Global Code Implementation
Developing and Implementing Policies for an Effective Program
APPENDIX 3-H: Sample Policy Prioritization Matrix
APPENDIX 3-I: Sample Policy Development Workflow
APPENDIX 3-J: Sample Policy Template
APPENDIX 3-K: Sample Policy Implementation Master Tracker
APPENDIX 3-L: Sample Communication Plan
Program Oversight and Management
Structuring the Chief Ethics and Compliance Officer and Compliance Function for Success: Six Essential Features of an Effective CECO Position and the Emergence of the Modern Compliance 2.0 Model
Board Engagement, Training, and Reporting
Yes, a Board can Positively Affect Culture: 10 Practical Actions
Delegation of Authority
Due Diligence in Hiring and Promotions: Implementation and Management
Education and Awareness
Essential Steps for Ethics and Compliance Program Branding and Marketing
APPENDIX 3-M: Branding and Marketing Resources
Training by Design
The Effectiveness of Compliance Training
Fraud Awareness Training: Enhancing a Low Cost, High Impact Control in Challenging Economic Times
3M’s Transparency Journey: Using Ethics and Compliance Cases as Teaching Tools
Onboarding as a Key to an Effective Compliance Program
Auditing and Monitoring
Auditing and Monitoring
APPENDIX 3-N: Compliance Audit Plan Example
Internal Reporting Systems
Why Employees Don't Speak Up - And How to Fix It
Hotline and Whistleblowing Reporting Mechanisms
Investigation and Response
Creating an Organizational Investigations Program and Conducting Effective Workplace Investigations
APPENDIX 3-O: Checklist for Assessing Investigation Capabilities
APPENDIX 3-P: Sample Internal Investigations Policy
APPENDIX 3-Q: Sample Upjohn Warning
APPENDIX 3-R: Sample Evidence Collection Worksheet
APPENDIX 3-S: Sample Key Allegations Worksheet
APPENDIX 3-T: Key Facts Worksheet
APPENDIX 3-U: Sample Investigation Report Form 1
APPENDIX 3-V: Sample Investigation Report Form 2
APPENDIX 3-W: Sample Policy Against Retaliation
APPENDIX 3-X: Instructions to Witnesses
Independent Investigations Overseen by the Audit Committee: Procedures and Guidance
Root Cause Analysis: A Critical Ethics and Compliance Practice for Getting to Why
What to Do When the Government Comes Knocking
Discipline and Incentives
Employee Discipline and Compliance
Using Incentives in Your Compliance and Ethics Program
APPENDIX 3-Y: Evaluation Form
APPENDIX 3-Z: Recognition Letter
APPENDIX 3-AA: Ideas for Using Incentives in Compliance and Ethics Programs
Risk Assessment and Management
Compliance and Ethics Risk Assessments
How to Protect Compliance Risk Assessments from Unwanted Disclosure
Third-Party Risk Management: The Who, What, Why, When, and How
Chapter 4: Measuring Effectiveness
Compliance and Ethics Program Self-Assessment: Key Considerations
Appendix 4-A: Compliance and Ethics Program Self-Assessment Questions
Methods and Guidelines for Demonstrating Compliance Program Effectiveness
Chapter 5: Specific Compliance and Ethics Risks
Anti-Corruption and Anti-Bribery
Anti-Corruption and Anti-Bribery Compliance Programs
APPENDIX 5-A: Additional Resources on Anticorruption and Antibribery
APPENDIX 5-B: Considerations in Initially Planning or Reviewing Your Training Program
APPENDIX 5-C: Checklist for Managing Third-Party Risk
APPENDIX 5-D: Common Red Flags Indicating Heightened Potential for Corruption
The UK Bribery Act 2010
APPENDIX 5-E: Bribery Act Resources
A Global Standard to Address Bribery Risk: ISO 37001: Anti-Bribery Management Systems Standard
Anti-Corruption Laws/Regulations in Latin America
APPENDIX 5-F: Latin America Anti-Corruption Resources
Corporate Compliance in a Geopolitical World: OFAC’s Framework for Compliance Commitments
Anti-Money Laundering
Anti-Money Laundering Compliance Programs for Financial Institutions and Other Businesses
Customer Due Diligence and Beneficial Ownership
Antitrust/Competition Law
Federal Antitrust Law Risks
APPENDIX 5-G: Federal Antitrust Law Key Resources
Antitrust Compliance in Canada
Antitrust Compliance Programs as Evaluated by the Antitrust Division of the U.S. Department of Justice
Conflicts of Interest
Conflicts of Interest
APPENDIX 5-H: Sample Policy on Conflicts of Interest
Conflicts of Interest: Evaluating Outside Board of Director and Advisory Service Roles
Gifts and Entertainment Compliance
Entity-Specific Risk Management
Government Agencies: Effective Compliance and Ethics Programs are Necessary for Public Trust
Environmental Liabilities
Environmental Law and Compliance
APPENDIX 5-I: The Swords and the Shields of Corporate Environmental Crimes
APPENDIX 5-J: Sample Self-Assessment Questionnaire for Environmental Compliance Programs
Compliance Professionals as the New Face of ESG Leadership
Government Contracting and Relationships
Government Contractor Integrity and Responsibility—Risks and Opportunities in the Federal Marketplace
Compliance Overview: Corporate Involvement in the Federal Public Policy Arena
Government Enforcement Actions and Disclosures
Voluntary Disclosure, Mandatory Disclosure, and Government Engagement
Corporate Probation: The Use of Independent Monitors to Improve Compliance and Prevent Fraud
False Claims Act Risks
APPENDIX 5-K: False Claims Act References to Key Resources
Identity Verification
Compliance and Fake IDs: Complications of Checking ID and Confirming Identity
Labor/Employment
Wage and Hour Compliance Under Federal and State Laws
Harassment in the Workplace: Leadership Impact and the Role of the Compliance and Ethics Practitioner
Building Cultures of Integrity in Remote and Hybrid Environments
The Changing Landscape of Cannabis Legalization: Compliance and Ethics Program Challenges
Mergers and Acquisitions
Effective Ethics and Compliance Due Diligence during Mergers and Acquisitions
Privacy and Data Protection
A Data Privacy Compliance Program Primer: A Snapshot of Data Privacy Regulations, Risks, and Compliance and Risk Management Effectiveness Strategies
Does GDPR Apply to My Organization?
The Role of the Data Protection Officer in Europe
Privacy in the European Union: A Data Safekeeping Revolution
A New Decade in Data Privacy: Complying with the CCPA
Bring Your Own Device Policies and Practices
Cybervigilance in Establishing Security Cultures
Cyber Insurance Guidelines for Corporate Compliance and Ethics Executives and Boards of Directors
APPENDIX 5-L: Determining Your Company’s Cyber Insurance Needs
APPENDIX 5-M: How to Prepare for and Reduce Costs for Cyber Insurance
APPENDIX 5-N: Common Cyber Insurance Mistakes to Avoid
Data Mapping: A Necessary Risk Management Tool
Security Incident and Data Breach Response
Records Management and Retention
Creating an Effective Data and Information Governance Program
APPENDIX 5-O: Sample Data and Information Management Policy
APPENDIX 5-P: Sample Retention Schedule Excerpt
APPENDIX 5-Q: Sample Litigation Hold Notice
APPENDIX 5-R: Sample RIM Decision Tree Tool
Social Media
Social Media Compliance
APPENDIX 5-S: Sample Social Media Policy
Supply Chain
Human Trafficking Prevention in the Supply Chain
Complying with the SEC's Conflict Minerals Rule: An Overview for Compliance Professionals
Technology and Compliance
Artificial Intelligence and Corporate Compliance
The Relationship between Technology and Compliance
Trade Compliance
International Trade and Business: US Export Controls
APPENDIX 5-T: International Trade References and Links to Key Resources
