Table of Contents

• Front Matter
  • Copyright
  • Editorial Advisory Board
  • Contributors
  • Preface
• 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
  • Ethics at Every Level: Safeguarding Your Organization from Misconduct
• Chapter 2: Foundational Materials and Program Infrastructure
  • Essential Elements of an Effective Ethics and Compliance Program
  • Appendix 2-A: Sample Letter to Vendors on Gift-Giving Limitations
  • Appendix 2-B: Model Anti-Retaliation Policy
  • APPENDIX 2-C: Sample Compliance Officer Job Description
  • Appendix 2-D: Sample Compliance Audit Report Form
  • Appendix 2-E: Sample Compliance Committee Member Confidentiality Commitment
  • Appendix 2-F: Compliance Issue Report Intake Form
  • Appendix 2-G: 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 Checklist
    • APPENDIX 3-B: Compliance Job Description
    • Appendix 3-C: Compliance Program Risk Catalog and Assessment
    • 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: Calculating the Value of Your Corporate Compliance Program
  • Compliance Standards and Procedures
    • Creating an Effective Code of Conduct and Code Program
    • Communicating Values Across Cultures: Globalizing Your Code of Ethics
    • Appendix 3-G: Considerations for Global Code Implementation and Rollout
    • Developing and Implementing Policies for an Effective Program
    • Appendix 3-H: Model Policy Management Policy
    • Appendix 3-I: Sample Policy Template
    • Appendix 3-J: Sample Compliance Policy Management Checklist
    • Appendix 3-K: Sample Compliance Communications Plan
  • Program Oversight and Management
    • Structuring the CECO and Compliance Function for Success
    • 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
  • Auditing and Monitoring
    • Auditing and Monitoring
    • Appendix 3-M: Sample Compliance Auditing and Monitoring Plan
  • Education and Awareness
    • Essential Steps for Ethics and Compliance Program Branding and Marketing
    • Appendix 3-L: Branding and Marketing Resources
    • Training by Design
    • Creating Effective 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
  • Internal Reporting Systems
    • Why Employees Don't Speak Up and How to Fix It
    • Hotline and Whistleblowing Reporting Mechanisms
    • Whistleblowing Legislation in the EU and Brazil
    • Appendix 3-N: Example Whistleblower System Policy Framework
    • Appendix 3-O: Checklist of Processes and Controls to Consider When Establishing a Whistleblower System
  • Investigation and Response
    • Creating an Organizational Investigations Program and Conducting Effective Workplace Investigations
    • Appendix 3-P: Checklist of Core Internal Investigator Competencies
    • Appendix 3-Q: Model Internal Investigations Policy
    • Appendix 3-R: Sample Upjohn Warning
    • Appendix 3-S: Sample Investigation Report Form
    • Appendix 3-T: Sample Investigator Script
    • Procedures and Guidance for Independent Investigations Overseen by the Audit Committee
    • Root Cause Analysis: A Critical Ethics and Compliance Practice for Getting to the 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-U: Sample Manager Evaluation Checklist
    • Appendix 3-V: Sample Employee Integrity Recognition Letter
    • Appendix 3-W: 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-bribery and Corruption Compliance Programs
    • APPENDIX 5-A: Additional Resources on Anti-Corruption and Anti-Bribery
    • Appendix 5-B: Considerations in Compliance Education Program Development
    • Appendix 5-C: Best Practices 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-Corruption Laws/Regulations in Latin America
    • APPENDIX 5-F: Latin America Anti-Corruption Resources
  • 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: Model Conflicts of Interest Policy
    • 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: Environmental Risk Factors and Mitigating Measures
    • Appendix 5-J: Environmental Compliance Program Self-Assessment Questionnaire
    • Compliance Professionals as the New Face of ESG Leadership
    • ESG, Cyber, and Privacy: Bridging the Divide
  • 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: Self-Assessment to Determine Cyber Insurance Risk
    • Appendix 5-M: Recommendations to Prepare for and Reduce the Cost of Cyber Insurance
    • Appendix 5-N: Common Cyber Insurance Mistakes to Avoid
    • Data Mapping: A Necessary Risk Management Tool for Data Compliance
    • Security Incident and Data Breach Response
  • Records Management and Retention
    • Creating an Effective Data and Information Governance Program
    • Appendix 5-O: Model Record Retention Policy
    • Appendix 5-P: Sample Record Retention Schedule Chart
    • Appendix 5-Q: Sample Litigation Hold Notice
    • Appendix 5-R: Sample Record Retention Decision Tree Tool
  • Social Media
    • Social Media Compliance
    • Appendix 5-S: Model 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
    • Data Analytics for Compliance
    • Ethics, Compliance, and Artificial Intelligence
    • Harnessing Technology for Auditing and Monitoring in the Digital Era
  • Trade Compliance
    • Corporate Compliance in a Geopolitical World: OFAC’s Framework for Compliance Commitments
    • International Trade and Business: US Export Controls
    • APPENDIX 5-T: International Trade References and Links to Key Resources
    • U.S. Antiboycott Laws: Understanding the Impact and Ensuring Compliance