Hui Chen Suggests Companies Focus on Ethics and Metrics to Move Beyond a Rules-Based Approach to Compliance

As much as corporations may seek a list of dos and don’ts from government regulators in the anti-corruption space, taking such a formulaic, rules-based approach to compliance is missing the mark, warned former DOJ compliance counsel Hui Chen during a presentation at Converge 17. Instead, companies should avoid treating their compliance programs like a checklist and focus on ethics, metrics and measurable results, she advised. Metrics should not merely be used to demonstrate the number of policies a corporation has on hand or to tick off the amount of training conducted, Chen said. Rather, data should be generated and evaluated to demonstrate how the “tone at the top” translates to actual conduct at the upper echelons and then trickles down to the rank and file. See our four-part series on measuring compliance: “Getting Started” (Aug. 2, 2017); “Seven Areas of Compliance to Measure” (Aug. 16, 2017); “How to Measure Quality” (Sep. 6, 2017); and “Gathering and Analyzing Data” (Sep. 20, 2017).

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