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Hofstra University Conference on Compliance and Culture of Integrity Monitoring and Auditing Compliance and Ethics Programs October 29, 2014 Leonard A. David SVP and Chief Compliance Officer
CORPORATE COMPLIANCE Compliance programs developed/implemented by business organizations to control risk of violations of law and policy, promote ethical conduct and thereby maintain/enhance corporate reputation. Federal Sentencing Guidelines set legal incentives to develop compliance programs and specified key elements: –Establish standards and procedures –Executive Leadership to be knowledgeable re: content/operations and have it resonate throughout the organization - - “tone at the top.” –Senior personnel to be assigned overall program responsibility: effectively “cascade” it throughout the organization Systematically communicate, reinforce and train all employees on program - - should become part of “corporate DNA" 2
CORPORATE COMPLIANCE Some Factors in Increased Attention to Compliance Matters, Worldwide –Globalization –Focus on Compliance/Ethics –Trend toward Corporate Social Responsibility –Increased focus on GRC (governance, risk, control) –Terrorism –Corporate Misconduct Cases –Increased Communication and Dissemination of News and Information - - Demand for Transparency 3
CORPORATE COMPLIANCE “You don’t need a weathervane to know which way the wind blows.” Bob Dylan Subterranean Homesick Blues 1965 4
CORPORATE COMPLIANCE “Just because I’m paranoid doesn’t mean they’re not after me.” Anonymous 5
MAIN TAKEAWAY While there are many legal, regulatory, organizational and societal forces impacting development of compliance programs, there’s no “One Size Fits All.” There are a variety of ways to implement, monitor and audit each program based on size, resources, industry, commitment and level of engagement of each unique organization. 6
CASE STUDY – HENRY SCHEIN INC. Henry Schein Operates its Businesses in a Complex Global Regulatory Environment 7
REGULATORY MAZE 8 FDA DEA IRS CE FAA VAWD EPA SEC ISO
WORLDWIDE BUSINESS STANDARDS 9 Our comprehensive legal and regulatory program is fundamental to our Company’s values- based culture Our Global Code of Conduct
COMPLEMENTARY/SUPPLEMENTARY CORE POLICIES 10
MONITORING WWBS Handbook/Orientation Independent outsourced training and testing, and biannual refreshers, for all employees worldwide in multiple languages Alertline Quarterly Reports to Audit Committee Periodic Reports to Board of Directors Compliance Committee – meets quarterly –Dedicated senior personnel including CCO 11
MONITORING Cultural Survey Internal Audit Outside Auditors Tone at Top – CEO buy-in and leadership reinforcement at virtually every management, executive management and full Board meeting –Institutionalizes a corporate Culture of Compliance 12
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