The third ingredient for a successful competition law compliance program: Policies and Procedures
This guest blog post is provided by the Competition Bureau, an independent law enforcement agency that ensures Canadian businesses and consumers prosper in a competitive and innovative marketplace. Headed by the Commissioner of Competition, the Bureau is responsible for the administration and enforcement of the Competition Act, the Consumer Packaging and Labelling Act (except as it relates to food), the Textile Labelling Act and the Precious Metals Marking Act.
As part of a series on Our Best Recipe for Compliance Programs, today we would like to introduce you to the third essential ingredient to ensure you comply with the law. In addition to having Buy-in from your manager and Assessing compliance risks, an effective compliance program should also include policies and procedures tailored to the operations of your business.
In our last blog, we introduced the importance of identifying the potential risks your company is facing and employees who may be at a higher risk of breaking the law. With this information on hand, you will be able to customize your compliance program to reduce such risks.
Policies and procedures are good tools to help your employees comply with the law. Those should fit your business' operations and target the risks previously identified. For example, if your company often submits bids, having a checklist of “dos and don'ts” as part of your internal procedures is a good way to create quick and easy reminders for employees, as well as a system of accountability.
Your policies and procedures should be distributed to all relevant staff or, ideally, all staff and it should be available in readily accessible and easy to understand language. Cooks might be the most likely to get burned, but all staff should be aware of safety procedures in the kitchen!
We have also mentioned in the past how you should keep an eye out for changes in your internal or external environment that could create new risks for your business. It is important to have mechanisms in place to update your policies and procedures according to those changes.
A chef's grocery list should always be adapted to their menu, just like your compliance program should always reflect the current operations of your business.
To learn more, please see the Corporate Compliance Programs bulletin available on our website.