In order to manage the design, training and education, and monitoring and auditing of the program, the company forms a cross-functional Compliance Committee. The committee is generally composed of management representatives from the Office of General Counsel, Human Resources, Internal Audit, and, most importantly, Operations. These compliance officers assist with program design, training and monitoring, and report to the Compliance Committee or Corporate Compliance Officer. Due Care when Delegating Authority Key Practices of Companies with Leading Edge Compliance Programs New employees who will be based in foreign countries and who will have significant authority dedicate a substantial portion of their initial employment with the company to learning about the company s values and culture. The company periodically rotates its chief financial officers among foreign businesses, particularly in those countries where corruption risks are considered high.
Agents participate in the company s training programs about corporate compliance.
Communicating about Compliance Key Practices of Companies with Leading Edge Compliance Programs Compliance program instructors are often a team of professionals from the Office of General Counsel and Operations management. Training is conducted at foreign locations as well as the home office in the United States. Training materials are translated into foreign languages. The timing and comprehensiveness of the training programs are influenced by such factors as increased employee turnover and changes in the legal and regulatory environments. More frequent training sessions are held in geographic regions with significant corruption risk exposure.