We’ve taken the liberty to review the updates and write up the top ten takeaways and immediate actions compliance officers can make in response. Why did we write these? Because we keep seeing legal analysis as opposed to practical steps to take to align your program with the new guidance. We’ve got you covered!
You’ve probably seen some coverage about the March 2023 update to the DOJ’s Evaluation of Corporate Compliance Program (ECCP) guidance. But most of the coverage we’ve seen is far too legal. It doesn’t tell us what we as compliance officers should do with the information about the updates.
Imagine the horror most people feel when they find out their company has engaged a supplier that has been using forced labor, child labor, or indentured servants to create the product.
The corporate “zero tolerance” statements come out, the lawyers are corralled, and the letter terminating the contract is signed.
Done, right?
Kristy Grant-Hart is a compliance and ethics expert specializing in transforming compliance departments into in-demand business assets.