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Management oversight

  • One of the most important things you can do is to ensure your employees and sub-distributors understand that you expect them to act with integrity. When you have business meetings or talk about competitive strategies, never forget to talk about the importance of acting with integrity.
  • It is essential that you respond to any issues or concerns. This will likely involve interviewing individuals and reviewing records.  The follow-up does not have to be extensive but must be sufficient to demonstrate a good faith attempt to find the facts and to reach a reasonable conclusion.  The follow-up must also be documented with at least a memo to file containing the following information: date issue was received, description of issue, reporter name if not anonymous, investigator name, persons interviewed and summary of interviews, records reviewed, conclusion as confirmed or not confirmed. If confirmed, also list action taken such as discipline (written warning, termination, bonus suspended), re-training, policy or process changes (additional controls) and/or additional monitoring and auditing.
  • It may be useful to designate a manager in the home office to be the point of contact for compliance, to be responsible for training, and to ensure follow-up of reported or detected issues.
  • It is important to monitor adherence to your compliance programme requirements. Follow these five easy steps to ensure the controls you put in place are being followed.
  • List of Accounts Payable red flags - give this reference to your accounts payable staff