Compliance Safeguards
Client Challenge: Even if you have all the compliance policies and documents in place, a vigilant manager still has to train the staff to understand and use them, and then to verify the effectiveness of these programs. Then, if problems do occur, is there a process for staff members to raise the issues and for responsible officials to deal with them in the safest, most responsible way? Specifically, the executive team must periodically ask the following hard questions:
Are there adequate resources for compliance training?
- Is both initial and ongoing training provided to staff?
- Are diverse training modes utilized, such as distribution lists, posters, bulletins, etc?
- Are key experts encouraged to attend industry export control functions?
Has an Internal Compliance Audit/Assessment been recently conducted?
- Was it performed by non-biased expert?
- Were deficiencies corrected and re-assessed subsequently?
- Was an Audit module created/utilized to ensure continuity?
Are there appropriate Internal Notification procedures in place?
- Are employees encouraged to raise compliance concerns?
- Are they trained to recognize gaps, irregularities, and aberrances?
- Is it clear how to raise these issues and that to do so is risk/retaliation free?
CTP Solution: We provide Customized On-site Training, based on adult learning principles, that combine government requirements, company specific policies, and corporate best-practices. We have a comprehensive Audit Process that measures the effectiveness of compliance measures, both against government requirements and against resources applied. Finally, we can help companies employ proper notification policies as part of our EMS Manual & Consulting services.
