Compliance Plans Should Reduce Risk, Not Create Liability
February 4, 2015
Attorneys Michael G. Considine from Seward & Kissel LLP and Christopher M. Favo from the 3M Company discuss the pitfalls of setting up a cursory or poorly thought out compliance program. Copying a program wholesale or cobbling one together from another industry, failing to staff a program appropriately, and failing to take enforcement seriously are among the practices to be avoided. “If a company doesn’t ensure that a compliance plan addresses the real risks the company confronts, and that employees can follow it in practice,” they write, “one might ask whether the company is better off with no plan at plan at all.”
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