■ ■ Commit to protect. Ensure that that the C-suite is outwardly supportive of creating and
honoring new compliance initiatives. This will set the tone for the entire organization.
■ ■ Spring cleaning. In-house counsel should perform a thorough due diligence of old
compliance policies to determine what needs to be revised. In doing so, the company
will have a clearer understanding of the probability of a compliance violation.
■ ■ Education dedication. Consider how your compliance training measures
are implemented and guarantee that each employee receives the
same message. This mitigates the risk of misunderstanding.
■ ■ Using the whistle. Be sure that the proper channels exist to report compliance
violations. These include confidential email, internet, and telephone “tip lines.”
IN SMALL LAW
By Stephanie Bortnyk and Carl Peterson In many legal departments, particularly
with those that qualify as “small,” the notion of devoting one’s already
scarce resources to designing, implementing, and monitoring a wholesale
compliance program can be horribly intimidating. But more than
overwhelming, it is also seemingly a luxury rather than a necessity in an
environment where legal departments are often being asked to do far
more with less.