In 2014, the US Department of Justice (DOJ) announced 21 Foreign Corrupt Practices Act (FCPA) enforcement actions. These are on top of untold investigations that they and the SEC launched into suspected violations. In most FCPA cases like these, there are multiple failures in the compliance and control program of the DOJ target, and a great many of these include a failure to effectively document, publish, and require acknowledgement of policies related to employee (and other stakeholder) accepted behavior.
At Mitratech, we see many of our clients responding to this gap with enhancements to their policy management programs, and use technology to support these efforts. Some firms are content with the automation of policy authoring and editing, review, approval, and publication. These solutions are useful in developing and maintaining a library of “policies of record”. Mitratech’s recent white paper, “At the Intersection of Legal and Compliance”, highlights the legal department’s role in governance, risk, and compliance. Specifically in policy management, “Firms have begun to recognize that a good policy management program, including solid awareness and education, as well as bullet-proof attestation, can be critical in reducing regulatory risk.”
More advanced clients are going one step further to ensure that their policy program is tightly integrated with their overall compliance framework. These clients are looking for additional capabilities to help them:
- map their regulatory (and other) obligations to their policy framework, so the right policies can be targeted at the right parts of their business
- assess compliance risks across their business and obligations, so that policies and related awareness and attestation programs can be targeted at the areas of highest risk
- have a unified access point for employees to see all of their applicable policies and required tasks, and for management to see the policy review and attestation status of the employees under their responsibility
- make their policies and attestation programs mobile-ready so busy, on-the-go employees can easily access the information they need to remain compliant
Here at Mitratech, we are proud that many of our leading client legal departments, like the Williams Companies, are using our solutions to meet these challenges, making their office of the general counsel the best-run function in their respective companies. We would love to discuss how we can enable your legal department to exceed goals and deliver more value to your organization.