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Obligations of a public company<br />
it is vital that managers and supervisors<br />
be involved in the communication of<br />
compliance standards and discussion of<br />
ethical culture.<br />
Organizations should undertake a<br />
data-driven approach to monitoring and<br />
auditing their compliance program. A<br />
company should be collecting data on<br />
the program that includes, but is not<br />
limited to, training, reporting, culture<br />
assessment and knowledge assessment<br />
and should utilize appropriate external<br />
benchmarking tools to assess performance.<br />
The FSG require that organizations<br />
provide an anonymous reporting<br />
mechanism; additionally, organizations<br />
must ensure that open-door reporting—<br />
and a commitment to nonretaliation—is<br />
encouraged and properly communicated.<br />
All organizations must ensure<br />
that investigations and discipline<br />
are consistent and as transparent as<br />
possible; this reinforces organizational<br />
justice and encourages reporting.<br />
Organizations should also seek creative<br />
and objective measures for performance<br />
and incentivize ethics and compliance at<br />
their organizations, as recommended by<br />
the FSG.<br />
Corporate compliance practices have<br />
undergone enormous change in a relatively<br />
short period of time and best practices<br />
are continually developing. The level of<br />
scrutiny of a board’s monitoring—or<br />
failing to monitor—the activities of a<br />
corporation has increased dramatically.<br />
The challenge for boards, executive<br />
officers and compliance officers now is to<br />
view the increased scrutiny and enhanced<br />
standards not merely as a host of new<br />
legal requirements but as an opportunity<br />
to review and enhance their corporate<br />
governance and compliance practices,<br />
setting a true “tone from the top.” ●<br />
72 NYSE IPO Guide