Establishing effective policies and procedures is fundamental to a successful organization, especially in an increasingly regulated business environment. Organizations must not only maintain proactive compliance programs, but demonstrate that these programs are effective and exercise reasonable oversight. According to 2011 Federal Sentencing Manual issued by United States Sentencing Commission (USSC), there are key elements that are essential to every compliance program.
1. Establish Standards, Procedures, and Controls
At the most basic level, an organization must establish a code of conduct that is consistent to its business environment. These policies and codes of conduct must be created, reviewed, approved, and distributed to employees in a consistent and structured process. ConvergePoint’s Policy and Procedures Management Portal is designed to streamline the creation process by managing the workflow in one structured place and process. The platform does away with confusing email chains and ensures all collaborators are efficient through a rules based approach to policy creation.
2. Implement Effective Compliance Measures and Exercise Reasonable Oversight
Once the organization has an established code of conduct, the various layers of management must be on the same page to ensure a consistent message is spread to its employees. Managers at an in-store level have a more practical application, and must have a way to effectively make changes to policy in real time. This may not be difficult for small companies, but on a global scale can be rather challenging to ensure a consistent message across management collaboration efforts. Create an effective message by using ConvergePoint’s Policies and Procedure Portal.
3. Exercise Reasonable Effort to Avoid Delegation of Authority to Unethical Individuals
Information regarding policy creation and implementation can be of sensitive nature “ confirm there are checks and balances in your policy creation to make sure individuals are creating policy that is not in personal interests. If an audit was to occur, with ConvergePoint’s Policy and Procedures Portal, management can track who collaborated on a policy or ensure that only authorized users made changes.
4. Communicate and Train Employees on Compliance
The organization’s code of conduct must be distributed and acknowledged in a consistent manner by every employee to be effective. The Policies and Procedures Portal automatically publishes policy PDFs in real time to selected distribution lists and tracks when policies are about to expire. The portal also tracks the receipt of policy by employees, and managers can require quizzes on published material to ensure employee comprehension and compliance.
5. Conduct Internal Monitoring and Auditing on Compliance Efforts
Mechanisms must be in place to sort through the policies and procedures so that if there was an incident or audit the employer can prove employee comprehension of conduct. Most companies currently keep policy documentation on shared drives, but finding the most current version or ensure employee certification can be tricky. With the Policies and Procedures Portal there is no guesswork, every document version is indexed, searchable, and retrievable. Managers can easily run reports to make sure all employees and procedures are up to date, taking a proactive stance on compliance implementation.
6. Provide Consistent Enforcement and Discipline for Violations
Organizations should frequently promote the relevance of such compliance implementation; by applying a structured means to create policy, companies are creating a clear message for employees. With the Policies and Procedures Portal, employers can be sure the employee acknowledged the policy, eliminating the excuse, œI just didn’t know. Disciplinary action can be implemented when the first incident occurs, setting a clear message for consistent enforcement.
7. Respond Appropriately to Incidents and Take Steps to Prevent Similar Criminal Conduct
What are the steps for action when a policy is broken, and how do you make sure that all managers respond similarly and appropriately? With consistent policies and procedures in one structured place, employers can ensure managers have the same call to action across the board. Proactive measures in The Policies and Procedures Portal allow real time changes to policy, version tracking, and automatic distribution of updated documentation to all pertinent employees.