Key Performance Indicators (KPIs) and tracking metrics are a fact of everyday life for business organizations. Both are tools used to measure and evaluate the success of a wide variety of actors and activities and anti-corruption compliance is no exception. Increasingly, companies and regulatory agencies are relying on metrics and KPIs in judging whether (1) a compliance program is being implemented in a robust and good faith manner; and (2) the elements of the programs, and the program itself, are effective in achieving their desired goals. In this first installment of 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, discuss the differences between KPIs and metrics in anti-corruption compliance programs, how metrics and KPIs can be used and relied upon to assess robustness and effectiveness, and how good KPIs and tracking metrics are developed. The second article will give examples of KPIs and tracking metrics that companies might consider for some of the primary elements of anti-corruption compliance programs. See also “Defining, Documenting and Measuring Compliance Program Effectiveness
” (Dec. 2, 2015).