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Mar. 7, 2018

Compliance Program Checkup: A Checklist for Evaluating Employee Discipline Policies and Procedures

  • Megan Zwiebel
    Anti-Corruption Report
Properly disciplining employees involved in an anti-corruption matter is a necessary and useful part of remediation. Companies should have good discipline policies in place before an anti-corruption issue arises to ensure that the procedure does not appear ad hoc or arbitrary to either employees or enforcers. When an issue does arise, companies should proceed with care to ensure a just and defensible outcome. This checklist provides companies with questions to ask both about their policies and specific procedures to make sure that their discipline process is running as smoothly as possible. For a deeper dive on this topic, see the Anti-Corruption Report’s three-part series on employee discipline for anti-corruption issues: “Predictability and Consistency in the Face of Inconsistent Laws” (Nov. 1, 2017); “Investigation and Documentation to Smooth the Discipline Process” (Nov. 15, 2017); and “Due Process for a Just and Effective System” (Nov. 29, 2017).

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