At any given time, one aspect of your compliance program is ineffective.
It’s normal. Your organization changes. The laws change. Society changes. Innovation happens.
It may be normal but it still needs to be addressed in a meaningful way. Publishing a policy and asking employees to certify their understanding of it does not earn you good grades from the regulators these days.
What, then, is a meaningful implementation of an effective compliance program? For that answer, let me turn it over to Hui Chen and Eugene Soltes. They’ve written great article for the Harvard Business Review, one that every ethics and compliance professional should read. Here is the link: https://hbr.org/2018/03/why-compliance-programs-fail.
The punch line: Organizations cannot build effective compliance programs without effective measurement tools.
How do you measure the effectiveness of your compliance program?
The Ethical Leader 