Actions by the U.S. Securities and Exchange Commission (SEC) have amounted to more than a billion dollars in disgorgement, fines and penalties every year for nearly two decades. On average, nearly a quarter of actions filed also included named individuals as defendants. What does it mean for your organization if one of your employees engages in illegal activity? Well, that depends. Can your organization provide evidence that your house is in order?
The executives who sleep well at night know that 1) they have policies in place, 2) they have and enforce a process to ensure policies and procedures are kept up to date, and 3) the organization has gone to great lengths to ensure that all employees and third-party agents of the company are aware of the policies and procedures.
Upon request, managers in their organizations can provide the latest policies, proof of maintenance, access to previous versions, a list of all changes including who made them and when, as well as evidence of employee notification and certification.
Employees in these organizations can also rely on their policy management systems to help them work more effectively and efficiently. Their policies and procedures are appropriately linked to related regulations, risks, controls, and principles, and they include ties to responsible parties, departments, relevant locations, and systems touched. If a new employee, system, or regulation is introduced, they can see who and what is impacted.
The most adept organizations have a broadly communicated philosophy regarding policy documentation and practices that provides a shared foundation for all divisions, departments, and regulatory management teams throughout the enterprise. They utilize a centrally accessible policy management platform that supports collaborative authoring and monitoring while also providing all employees with easy access to the latest approved versions.
How well have you been sleeping? Reach out to us and soon you can rest, too, knowing your house is in order: 412.263.3318.
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