BENEFITS OF A COMPLIANCE MATURITY MODEL
With the many agencies that make up the total of the US federal government, there are only a handful of documents released that are likely to catch the full attention of a corporate compliance officer. One of those documents was released by the criminal division of the US Department of Justice (DOJ) earlier this summer – an update to its guidance on the evaluation of corporate compliance programmes, and many compliance officers may still be fretting over its contents today.
Of the many benchmarking tools that may be used to evaluate the efficacy of a compliance programme, few hold as much weight as the DOJ guidance comments that have been issued only two other times since the initial guidance was published in 2017. The guidance is actually intended for a different audience, specifically federal prosecutors, to assist them in making informed decisions about whether a company’s compliance programme was effective at the time of the offence and whether it is effective at the time prosecutors make charging decisions. That said, the importance of these occasional releases is far more wide-ranging because companies, insurers, lenders, accountants, lawyers and others often use the guidance as a resource to measure the effectiveness of corporate compliance programmes in other settings. Hence the fretting of the compliance officer that wonders how best to perform an evaluation of their programme without breaking their budget and the time drain associated with a full-blown programme assessment from a major consulting agency.
However, there is an assessment tool available which, with some initial investment to properly calibrate to the programme it will be used to judge, can not only provide a reasonably quick answer to whether a programme is on track with the government’s guidance updates, but also serve as a living roadmap for a programme to achieve higher levels of efficacy and recognition within the company. That tool is a maturity model.
Oct-Dec 2020 Issue
Cargill Incorporated