Hi, we are looking for or trying to get an idea of how other companies assess if their corporate policies/procedures that address/prohibit misconduct (i.e., gifts & entertainment, policy on independence, standards of conduct, insider trading, code of conduct, etc.) have been implemented effectively. Basically do employees know about them, understand them, follow them, is the message getting out there, etc. Some of these policies might be owned by compliance and some might be owned by other departments. Wonder if anyone could share their practices or how they handle this assessment. Thanks.
Most policies at my company rely on procedures for implementation. Individuals in the business lines typically know where to find and how to use procedures. Business lines need to confirm that the policy is fully implemented, meaning procedures are written and in place. Some over-arching policies are communicated through one-off efforts/meetings, or connected to our Code of Ethics (which is much publicized throughout the year).