“What are the dos and don’ts of written compliance policies?” & Three Questions with Wesley Bizzell

Written standalone policies, along with your code of conduct, form the foundation of an effective compliance and ethics program.  Often organizations focus on rewriting and redesigning code of conduct to meet current best practices and do not consider rewriting standalone policies, even though most codes of conduct reference these other policies.  It is important to note that the Sentencing Guidelines don’t mention code of conduct specifically, but the Guidelines do require that an organization establish standards and procedures to prevent and detect criminal conduct.  When you are updating your code of conduct, you should also be considering the policies it references.  Many of best practices developed over the past few years  focus on rewriting your code of conduct to make it more accessible. These same lessons apply to writing effective policies. In this episode, Eric answers: How do you ensure your policies are reasonably capable of preventing and detecting criminal conduct as required by the Sentencing Guidelines? What lessons can you apply to writing standalone policies from code of conduct best practices? How do you create consistency across all your organization’s policies? How do you effectively work with subject-matter experts and other stakeholders within your organization to rewrite policies? The Upshot There are some key things to keep in mind when you are planning to update your standalone policies.  The types of stakeholders and subject-matter experts who you will have to consult with are wider and broader than the ones you consult with when rewriting your code of conduct.  It will take planning to get them aligned with the end goal.  Just as you would in a modern code of conduct, you need to pay attention to the language you use in your policies. Try to reduce jargon and have a conversational tone.  Consider design and interactive learning aids where possible.  Also, develop a template so that you have a consistent approach across your policies. Three Questions with Wesley Bizzell, Assistant General Counsel and Director of Political Law and Ethics Programs, External Affairs for Altria Client Services Inc. At Altria Client Services, Wes provides in-house legal counsel on matters relating to the political, legislative, and lobbying activities of Altria Group, Inc., its services companies, including Altria Client Services, and its operating companies, including Philip Morris USA Inc., U.S. Smokeless Tobacco Co. LLC, John Middleton Co., and Ste. Michelle Wine Estates Ltd. He’s responsible for ensuring that Altria and its companies comply with all laws and regulations regarding federal, state, local, and international campaign finance, government ethics, gifts to government officials, lobbying disclosure and reporting, and charitable giving. Overseeing a comprehensive compliance system covering the regulation of government affairs, Wes provides advice and guidance on political law compliance for more than 75 jurisdictions. He also heads the legal team that supports Altria’s public policy activities, providing services related to legislative and regulatory drafting and interpretation. Mr. Bizzell is a member of Altria’s Compliance Leadership Team and its Anti-Corruption Compliance Working Group. If you have a question you want answered on the podcast be sure to submit it on here or reach out below.  https://twitter.com/eric_morehead <a...