Do your customers trust and believe in your company? Do you trust and believe your employees? Do your employees trust and believe in you?
In November 2012, the criminal division of the U.S. Department of Justice (DOJ) and the enforcement division of the U.S. Securities and Exchange Commission (SEC) jointly released A Resource Guide to the U.S. Foreign Corrupt Practices Act (“the Guide”). While the 130-page guide is packed with useful information and written in an approachable style free from legalese, it provides perhaps its best and most useful information beginning on page 57 in the section titled, “Hallmarks of an Effective Compliance Program.” In the in introduction to this section, the authors note that there is no such thing as a one-size-fits-all compliance program, and that it is expected that small to midsize companies’ compliance programs will very likely differ from those in place at much larger organizations. They also point out that companies may consider a variety of factors in tailoring a compliance program to their specific organizations.