New Directions in Corporate Compliance: Keynote Luncheon Speech

Bonjour à toutes et à tous, très intéressant synthèse d’une intervention sur l’importance et ;les éléments nécessaires à un programme de conformité effectif par Andrew J. Donohue pour le compte de la SEC : « New Directions in Corporate Compliance: Keynote Luncheon Speech ». En lisant ce résumé, vous partagerez mon sentiment : il y a du travail en perspective !

Throughout my career I have witnessed that a critical component of an effective corporate compliance program is the integrity of those people you have in your organization and their ownership of personal responsibility for themselves and the areas for which they are responsible.  If you don’t have the right people with integrity who accept responsibility, the likelihood of your corporate compliance program being effective is, at a minimum, diminished appreciably….I can’t stress enough the critical role a firm’s culture has on its corporate compliance program and its effectiveness.  A culture of always doing the right thing, not tolerating bad practices or bad actors is essential.  The culture should encourage people to ask questions and to discuss openly what is the proper response to a particular issue and how conflicts should be resolved.  It should hold the higher up members of the firm to at least the same standard of conduct as those below them.  I have always thought that the higher up you were in an organization, the less tolerant the firm should be of your non-compliance.  If that is the culture of the firm that sends a powerful message within an organization. Another sign of the culture of a firm is whether there is a correlation between ethical behavior and the firm’s reward structure, such as salaries, bonuses and promotions (…)

 How did I get comfortable? So how do you get comfortable having responsibility for the corporate compliance function in a firm?  Now that is a good question.  I never really got comfortable and I was always worried.  But that was ok as it kept me constantly alert and thinking and I was able to sleep most nights.  Here are a few thoughts on how you might get more comfortable with these responsibilities:….”.

À la prochaine…

Ivan Tchotourian

Ce contenu a été mis à jour le 4 juin 2016 à 11 h 56 min.