Haynes and Boone, LLP
  August 1, 2003 - Dallas, Texas

The Components of a Corporate Compliance Policy
  by Lori A Feathers

Introduction All companies that engage in international commerce, whether large or small, should develop and implement a corporate compliance policy and training program so that employees, whether based in the US or abroad, are aware of conduct that could create liability for themselves or their company. The compliance program should require employees at all levels of the company to verify in writing that they have read and understand the company’s corporate compliance program, and compliance training should be mandatory for all employees. In addition, a high-ranking company executive should be named as the company’s Corporate Compliance Officer. Doing so will demonstrate to employees (and if need be, the U.S. government) that the Company considers compliance a serious matter, and it also will stream-line company communications regarding compliance issues. Among the benefits of having in place an effective corporate compliance and training program are: creation of a culture of compliance where violations are discouraged; detection of wrongdoing by employees and management at an early stage, sometimes before violations trigger civil or criminal penalties; and demonstration of a good faith effort to comply with U.S. law; and mitigation or waiver of penalties under the United States Sentencing Guidelines. Below is a brief summary of certain federal laws and regulations that affect international trade and investment activities. Guidance on how to comply fully with these laws and regulations should form the basis of any corporate compliance program.


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