An organization has documented policies and procedures in place to lay a foundation for the planned programme. These documents aim to provide the users a thorough understanding of the responsibilities and the actions which are expected out of them.
Developing a compliance programme from ground zero and continuously updating it is indeed a lengthy process. A tool like VComply can automate such compliance programme with ease. It has a ready-to-implement Compliance Library which enables an organization to focus on the implementation rather than the data collection.
A Compliance Programme of an organization should be a documented guideline of procedures which establish standards of conduct to meet the Governance guidelines, Internal Controls and Compliance essentials. Thus, it must contain –
- A commitment to comply with regulations
- Strategic goals and objectives of the organization
- Clearly documented responsibilities of the workforce, third parties and other stakeholders which meet certain organizational benchmarks
As per FCPA Report, the following areas of the compliance programme should be documented –
Governance and Oversight
An organizational graphical chart can be used to integrate all the information. Thus, it enables the workforce to identify all of the interested entities throughout the company that is responsible for compliance. Also, a well-documented board minutes are a definite source of data for auditors and regulatory bodies. Job descriptions, as well as Segregation of Duties, should be in place to avoid miscommunication and hassle.
Policies Procedures and Controls
A well documented Internal Control framework is a culmination of a robust GRC programme. Not all compliance areas are centralized. Thus. the compliance officials must be alert about documenting any change in the programme.
An ideal risk assessment programme is where there is a documentation of
What risk it is going to measure
How it is going to measure the risk
Who is entrusted to do the measuring
What is the frequency of measurement
A company is back to square one if it identifies a risk and fails to act upon it! Mitigating risk is as important as identifying it in the first place.
Training and Communication
Customize the training programme to employees’ specific job. To avoid “ Training Fatigue”, train the employee only for his share of GRC responsibilities to begin with. Hence, conduct it wisely, yet, regularly.
Audit and Monitoring
Third-party audit reviews and monitoring are necessary. It ensures the effectiveness of a compliance programme. Utilize technology wisely to achieve this objective. VComply’s Compliance Workroom helps an organization to collaborate and communicate with auditors on a common platform. Thus, it helps them create an audit trail and monitor it continuously. Following are a few ways to achieve this –
An organization should be mindful of framing and documenting compliance programme for the high-risk areas. Review all the documents should be under the guidance of legal experts/governing committee. Also, the organization can use technology to manage its GRC programme. To read more, click here. Also, training the workforce after finalization of the policies is also an important step of the entire process. The organization may additionally follow the below practices :
- Use of standardized templates to create consistency throughout the organization
- Easy to follow and user-friendly documentation
- Updation of policies and procedures as per changing regulations
- Providing easy access to the compliance programme document to the entire workforce
- Continuous verification as well as monitoring the functionality of the documented policies
- Measuring the outcome of the framework and comparison of quantitative metrics