The DOJ’s new guidance for evaluating corporate compliance programs put the spotlight on organizational justice, or what we might simply call fairness.
This question was added to Monday’s version of the guidance: “Does the compliance function monitor its investigations and resulting discipline to ensure consistency?”
That new question appears under the heading “Consistent Application.” That part of the guidance already asked: “Have disciplinary actions and incentives been fairly and consistently applied across the organization? Are there similar instances of misconduct that were treated disparately, and if so, why?”
‘Enforcement 40’ for 2020
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