They reported that Corpedia’s holistic approach was the only one of its kind to meet all the needs and concerns the client had from the perspective of measuring compliance risk and assessing their compliance program.

Fully Assessing Risk After a Complete Compliance Program Revamp

Overview

The client has international operations, and with these operations, several points of potential risk. Working in the food consumer products industry, the organization has a keen interest in preserving its good name. In collaboration with Corpedia, the organization launched a compliance risk assessment that not only identified areas that have improved over time, but also areas in need of further assistance and growth.

Problem

In light of the recent focus on anti-corruption and previous organizational pain points in this area, the client had worked internally to revamp their existing compliance program including a risk assessment and creation of an anti-corruption policy. Thereafter, the client wanted to ensure that they were in alignment with industry best practices as well as the U.S. Federal Sentencing Guidelines (FSG). The client felt that not only would a third party be valuable from an FSG benchmarking standpoint, but for an external, unbiased perspective and stamp of approval.
This is best practices guidance. The updated guidance to the FSG states….

Resolution

After issuing an RFP to several organizations, including the more “typical” organizations for enterprise risk management and assessment, they reported that Corpedia’s holistic approach was the only one of its kind to meet all the needs and concerns the client had from the perspective of measuring compliance risk and assessing their compliance program.

Corpedia thoroughly reviewed the following types of information:

• Employee cultural perspective
• Employee knowledge awareness
• Senior management compliance input
• Compliance program assessment
• U.S. Federal Sentencing Guideline and peer benchmarking
• Key compliance personnel interviews

Due to the large employee population without email or online access, the client needed a unique solution to reach this employee audience. Corpedia simplified the survey language to speak to a broader audience.  Then the surveys were translated, printed and shipped to various locations with off-line employees. The surveys were distributed to employees in various methods that worked best for each location, then sealed in envelopes and shipped back to Corpedia’s headquarters where they were manually entered into the survey system so all participating employees could be a part of the information gathering process and ultimately, the results.

In addition, Corpedia did a thorough assessment of the client’s compliance program and spoke to key personnel who either worked in compliance, or had a day to day responsibility for an aspect of compliance. Putting all of this information together, Corpedia’s analysts were able to create a unique compliance risk universe along with a report detailing findings and recommendations for mitigation of risk and compliance program improvements.

Outcome

Compliance program analysis of the client’s policies, training, communications, prior internal investigations and so forth provided reassurance by recognizing where they had succeeded during their internal program revamp. The client now has a more clear understanding of their organizational risks and has worked this into a roadmap for current and future improvements based on the prioritization of risks and Corpedia’s recommendations.

What’s more, they have engaged resources from multiple departments including compliance, legal, audit, HR and other divisions that play a key role to inform the compliance team and also to set the tone internally. By making this a multidisciplinary effort throughout the organization, this increases the internal buy-in and motivation to improve compliance efforts.
Additionally, the report provided at the conclusion of the risk assessment and overall compliance program review has been presented to the management team and the audit committee from a high level to convey key points as to where the client is doing well, and where growth is necessary.

The compliance risk assessment has played a central role to educate leadership and compliance personnel on the level of priority and importance of ethics and compliance risks by providing a unique risk universe for the client. This has aided the client by helping the leadership to make more informed decisions on next steps for topic-based training, ethics and compliance program updates and targeted communication efforts to the employee population.
In the future, the client plans to implement improvements and revisit the compliance risk assessment process to measure ongoing growth and target emerging areas of risk or new areas of focus that may need organizational attention.