25.01.2019

Committing to and implementing an ethics and compliance program often means the need for big changes in how the company operates, and changing the status quo is never easy.

Challenging entrenched practices both within the company and in its relationships with customers, government officials, and other stakeholders can be a considerable challenge that the CECO, the board, and senior management must face. Don’t try to do it all at once: focus your resources on low-hanging fruit (such as reviewing and improving policies and procedures) to show the value of compliance for the company while building a track record of success. In these efforts be sure to focus on the uniqueness of your company: how does your compliance program make sense for you?

An easy place to start is with a register for gifts and entertainment. Ensure that the policy defines when approval is required and that all given and received items must be recorded (honestly) in a register.

Create a process to do random checks periodically and make sure support staff knows the process. One policy might be “no entertainment during periods of negotiation of a business deal.” Another place to start could be conflicts of interest.

It is relatively easy to set up a process of clearances through the company’s email system and for the compliance department to be custodians of the register of all such clearances.

We must always remember that there are resources and networks of support.

Source: Center for International Private Enterprise

This material has been prepared in the scope of the “Armenia: Promoting Anti-Corruption Conduct and Reforms” Project implemented by the “Center for International Private Enterprise”, the “Armenian Lawyers’ Association” NGO, the “Corporate Governance Center” NGO and the “Yerevan Chamber of Commerce and Industry” with financial support of the National Endowment for Democracy. The project is implemented as a co-financing to the “Commitment to Constructive Dialogue” action implemented with the financial support of the European Union by a Consortium comprising the “Armenian Lawyers’ Association” NGO, the “Armenian Center for Democratic Education-CIVITAS” NGO, the “International Center for Human Development” NGO, the “SME Cooperation Association” NGO, the Union of Communities of Armenia, as well as “Agora Central Europe” NGO (Czech Republic). The contents of this material are the sole responsibility of the “Armenian Lawyers’ Association” NGO and can in no way be taken to reflect the views of the National Endowment for Democracy and the European Union.