The fifth ingredient in a world-class ethics and compliance program

Key differentiators​

What separates a “good” ethics and compliance program from a “great” one? While there are a number of factors that separate the “good” from the “great,” in our experience, there are five factors that are key differentiators in the highest performing compliance programs:​

• Tone at the top
• Corporate culture
• Compliance risk assessments
• The chief compliance officer
• Testing and monitoring​

Click here to download a compendium that provides details about all five ingredients. This 32-page document allows for easier reading and reference.

Testing and monitoring

Many ethics and compliance professionals use the terms “testing” and “monitoring” interchangeably. While testing and monitoring may be two sides of the same coin, and one cannot be fully optimized without the other, they are not interchangeable. In fact, both their design and desired outcomes are quite different. Commonly recognized definitions of each are as follows:

• Testing program: A dynamic, risk-based, independent compliance oversight process designed to periodically select and review a sample of business products, services, communications, and other areas to gauge and report on the operating effectiveness of compliance controls and/or adherence to stated policies and procedures.
• Monitoring program: The ongoing surveillance, review, and analysis of key business performance and risk indicators that allows the organization to identify potential compliance violations. While many seek to implement “automated” monitoring programs, monitoring activities can be either automated or manual.

Going from good to great

Great testing programs have a number of common attributes:

• Compliance is tested at the level of accountability
• Programs draw on a range of skillsets
• The program is designed using a risk-based approach
• ​​They are repe​atable and statistically valid

Great monitoring programs have a number of common attributes:

• The key risk and performance indicators the program monitors are meaningful
• Program owners understand how to harness the power of data
• As with testing, repeatability is key

As organizations look to establish best-in-class ethics and compliance programs, testing and monitoring is one of the essential components they need to build and leverage. With robust testing and monitoring programs, a company can not only gather critical information on weaknesses in their compliance program, they may also have advanced warning of any looming problems before they become significant and potentially damaging. That alone makes testing and monitoring one of the key ingredients of a world-class ethics and compliance program.