Compliance Podcast Network – In the DOJ’s 2024 update to the Evaluation of Corporate Compliance Programs (2024 ECCP), compliance professionals face new expectations that could reshape how we approach compliance programs. In this latest update, the DOJ strongly emphasizes data-driven insights, focusing on compliance culture, employee engagement, and organizational trust.
Data has taken on greater importance in the latest ECCP standards both in identifying risks as well as demonstrating the impact of the compliance program. Culture audits provide the data to identify not only how strong the culture of compliance may be, but also areas for strengthening. Accordingly, employee surveys should include not only ratings, but opportunities for respondents to provide more details on what works and what doesn’t.
The Compliance Podcast Network offers five practical steps that will elevate a compliance program:
- Implement regular culture audits. (Google Forms and Survey Monkey make it easy to issue employee surveys and compile the results.)
- Prioritize data collection and analysis. (At the very least, check data on visits to your organization’s code of conduct and hotline webpages to establish a baseline and track usage over time.)
- Enhance transparency and communication. (If you don’t have a regular ethics/compliance newsletter, at least get senior executives to send reminders and messages regularly.)
- Integrate compliance with performance incentives. (In a staff meeting, acknowledge a colleague’s quick thinking or reporting of a concern.)
- Document, document, document. (Senior management should also review it or at least read the report.)
The DOJ has raised the bar in its latest ECCP guidance. They are expecting to see organizations meeting these standards now. If OIG ever asks about your compliance program, your answer should not begin with, “We were just about to….”
Source: The Compliance Evangelist: Why the 2024 ECCP Update is a Game-Changer for Compliance
