Developing Key Performance Indicators and Tracking Metrics for an Anti-Corruption Program (Part Two of Two)

Key Performance Indicators (KPIs) and tracking metrics, regularly used to measure and evaluate the success of a variety of business actors and activities, are increasingly being used to take the temperature of a company’s compliance department as well. A company can use KPIs and metrics to help determine (1) whether its compliance program is being implemented in a robust and good faith manner and (2) whether the elements of the program, and the program itself, are effective in achieving their desired goals. In a two-part guest article series, Jonathan Drimmer, vice president and deputy general counsel at Barrick Gold Corp., and Matthew Herrington, a partner at Steptoe & Johnson, provide a guide for developing and using KPIs and metrics in anti-corruption compliance programs. The first article outlined how to develop and use metrics and KPIs to assess robustness and effectiveness. This second article provides specific examples of KPIs and metrics that can be used to evaluate many of the hallmarks of an effective compliance program, as identified in the DOJ/SEC FCPA Resource Guide.

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