Fcpa Compliance Report

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation.” But more than simply hotlines, companies have to make real efforts to listen to employees. But you must spend time working on this issue. You need to have managers who are trained on how to handle employee concerns; they must be incentivized to take on this compliance responsibility and you must devote communications resources to reinforcing the company’s culture and values to create an environment and expectation that managers will raise employee concerns.  The reason is that its own employees are a company’s best source of information about what is going on in the company. It is certainly a best practice for a company to