Evaluation of Compliance Program of a Multidivisional Organization

Corporate compliance has become a vital issue for many organizations. They must both have effective compliance programs that aimed at the prevention and detection of illegal conduct and prove their effectiveness. The focus of this study is a compliance program in a multidivisional company that is of Russian origin with trading abroad. The purpose of the study is to evaluate the compliance program and provide the company with recommendations for its improvements. To investigate the effectiveness and the quality of the compliance program the author chose to adopt the ethics audit developed by the Russian Business Ethics Network Association and made it more oriented at compliance issues. Moreover, in accordance with recommendations of the U.S. Sentencing Commission and the Department of Health and Human Services, there was conducted an electronic survey for employees of companies within the holding. Its purpose was to identify the employees' attitudes and perceptions of the compliance function in the company. The methods of data collection in the study are the survey for employees and interviews with compliance managers of the company and its competitor. Data of the survey were analyzed by applying the qualitative method and led to a general understanding of the compliance culture in the company. Data received from the interviews were used during the audit and development of recommendations. The adopted methodology of the RBEN audit investigated the compliance program in 11 directions and a total of 162 indicators were evaluated. The results of the study form the comprehensive overview of needed improvements in the compliance program in the company N. The detailed recommendations also give examples from different companies and provide the management of the company N with the information on both the preferable changes and possible approaches to it.