have a practical element to it, linking the compliance
programme to your daily business activities. Role-play is a
good way of identifying problematic areas; bringing together
staff with similar duties to discuss scenarios around the specific
realities of their work. Each individual should be given
his/her own copy of the compliance programme and once the
initial training has been completed, each individual member
of staff should sign a declaration, stating that they have read
and fully understand the compliance programme and that they
have received appropriate training. The compliance programme
should also be included in induction and training for new staff
members.
management and staff, the next step is monitoring progress.
This involves monitoring of business activities and proper use
of the compliance programme. As with training, monitoring is
an ongoing process and it is a good idea to include it as a
management function and to report on it in regular
management reports.
part of the compliance programme are effectively preventing
breaches of competition law. It also makes managers and staff
aware that they are being monitored, which should increase the
programme's overall uptake, effectiveness and success.
can help detect and address possible breaches of competition
law. Checks should be done on both paper and computer files,
including e-mail correspondence, especially of staff and
management who are most likely to be involved in
anti-competitive practices. If during this process something of
concern is uncovered, you should immediately place all
documents and electronic files to one side for safe keeping.
Contact your legal adviser and consider making an application
for immunity under the Cartel Immunity Programme.
law and to conduct business ethically
management, code of conduct and disciplinary
policies
compliance programme, and ongoing training
programme