Paul Moskal and Nick Mineo have authored a new piece titled, “Compliance Program Key to Building an Ethical Business Culture,” for the Buffalo Law Journal. The article recognizes that “No company is perfect. And every company will make mistakes to some varying degree during their lifetime. Knowing this, the best path to fostering an ethical business culture rooted in integrity and minimizing risk lies in the creation of a corporate compliance program. Well-designed compliance programs provide the tools beyond aspirations necessary to build an infrastructure that promotes and ethical culture.”

Further into the article, Moskal and Mineo outline foundational steps key to building a strong compliance program they’ve developed through CORE Consultancy, LLC. The full piece can be read online, here’s a key excerpt:

  • Establish an ongoing training program: Training programs are the best opportunity to ensure employees are aware of the risks associated with their line of work. The program should not be one-size-fits-all, but rather customized for different teams (your IT team faces different risks than HR managers). Proper training is a key step in helping employees to avoid risky behavior.
  • Solidify internal controls: Training will help well-intentioned employees identify and avoid risks, but it won’t stop that malevolent, rogue employee who is hell-bent on breaking the rules and doing things his or her way. Having internal controls to serve as “trip wires” to sound the alarm whenever there is initial violation of policy or procedure can serve this purpose.

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