General Compliance Topics

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  • 1.  Decision tree on when to contact compliance

    Posted 07-17-2022 03:34 PM
    Good afternoon,

    I'm looking for a decision tree or similar document to share with senior and departmental leadership on when to contact compliance, or a compliance v. human resources template.  I want them to know when to reach out as they often handle matters on their own or reach out to the wrong person/department.  Thank you in advance!

    Mia Harmon
    Privacy Officer & Compliance Manager
    D4C Dental Brands
    SCCE Membership

  • 2.  RE: Decision tree on when to contact compliance

    Posted 07-18-2022 08:24 AM

    Thanks for asking that question!  I don't have any resources for you, but I've also been considering some type of training around a "Compliance" need vs. an "HR" need.  I hope someone responds with helpful advice.  

    Tara Martin
    Director, Ethics & Compliance
    Delek US Holdings, Inc.

    SCCE Membership

  • 3.  RE: Decision tree on when to contact compliance

    Posted 07-18-2022 10:39 AM
    Hi Mia,
    We have the same issue. Per our Compliance Handbook, here are the types of issues that we've determined should be reported directly to Compliance:
    • Fraud
    • Violation of specific federal/state statutes and regulations
    • Gross mismanagement of federal/state grants or funds
    • Substantial, specific danger/hazard to public health and safety
    • Criminal offense likely to cause physical harm
    • Ethics violation or improper solicitation for contributions
    • Material breach of contractual program requirements
    We still get reports that I end up turfing to HR; I just follow up with the reporter to let them know that the report has been forwarded to HR and that they'll be following up going forward. I'd much rather have someone file a Compliance report and have to turf it to HR or a different department, rather than have no report filed at all. And I've had some reports where both Compliance and HR issues are in play, so we end up investigating the case in tandem.
    Hope this helps!
    Have a great day.

    Megan Nelson
    Senior Compliance & Privacy Officer
    Western Reserve Area Agency on Aging

    SCCE Membership

  • 4.  RE: Decision tree on when to contact compliance

    Posted 07-18-2022 10:57 AM
    Hello, Escalation is partly based on how your ethics & compliance program is scoped. For example, at Xylem the Harassment Prevention Program is managed by the ethics/compliance team. We also have a very small ethics/compliance team and rely on HR, regional Legal attorneys, Safety colleagues, etc. to help investigate matters. Here are matters that we ask be escalated to ethics and compliance:
    • theft
    • misuse of confidential information
    • conflicts of interest
    • dishonest record keeping or reporting
    • intentional circumventing of internal controls
    • expense report violations
    • bribery
    • price fixing, collusion with competitors, customers or suppliers
    • harassment, discrimination or retaliation
    • violations of law
    • violations of our policies

    Ann Kulow
    Global Ethics & Compliance Manager
    Xylem Inc.

    SCCE Membership

  • 5.  RE: Decision tree on when to contact compliance

    Posted 07-20-2022 09:47 AM
      |   view attached
    Hi Mia,

    This may not be exactly what you're looking for as its audience is our general employee population (not just senior and departmental leadership), but our office has developed a roadmap to point employees to the most efficient route for different types of concerns. I've uploaded it here. We've found the roadmap helpful in reducing the number of places an employee may "shop" their concern before reaching the appropriate unit.

    Emmilee Racek
    Compliance & Ethics Specialist
    Montgomery College
    Rockville, MD


    Roadmap.pdf   108 KB 1 version
    SCCE Membership