CEO Message: Tone from the top – Volume 1
03 Feb 2017
For our firm to have a good ethics and compliance programme we need to concentrate on the following:
- Tone from the Top - The starting point of any good ethics programme begins from the top. Partners and senior management must show the sense of responsibility and they must “live” the values of ethics and compliance. They must strive to empower all other management and staff to carry out the same sense of responsibility.
- Corporate Culture – A culture of integrity and quality is central to any effective ethics and compliance programme. Partners and senior management again play a vital role in ensuring that the corporate culture should always embody integrity and quality first and foremost.
- Risk assessments – Ethics and compliance risk assessments are a vital core in this programme. Partners and senior management must put in place assessments that will focus on the risks that are significant in their firms, and will assist in providing the basis for determining the actions necessary to avoid, mitigate and remedy these risks.
- Managing Partners of the individual offices must take up the responsibility of compliance officer within their firms. It will be their duty to set the “Tone at the Top” and ensure it is complied with through the ethics and compliance programme always ensuring integrity and quality.
- A testing and monitoring programme must be put in place so as to gauge the effectiveness of the ethics and compliance programme. Appropriate controls need to be implemented at the outset but need to be monitored for effectiveness on the ethics and quality.