11/17/15: An article by Jeff Kaplan for Corporate Compliance Insights focuses attention on an oft-overlooked aspect of corporate compliance: the compliance and ethics responsibilities of company managers. Kaplan acknowledges typical duties such as leading by example and maintaining...
a “speak up” environment, but he writes, “Somewhat less frequently one also sees mandates to serve as a ‘champion’ of the C&E program, make sure that the employees in their unit understand how the code applies to their respective jobs and be alert to C&E risks.” According to Kaplan, managers’ abilities to fulfill their duties require reinforcement. Okay, but what kind of reinforcement exactly? Fortunately, Kaplan identifies several forms that could work.