to establish whether the compliance procedures and monitoring mechanisms are working well. The review should look at whether the programme is properly resourced and supported by senior management, if it is operating properly, whether compliance measures are appropriate and if the desired results are being achieved. initial risk assessment are still valid and if the programme still addresses those risks. The review should also look at the level of training and whether it is effective. independent person, who was not involved in the design and implementation of the compliance programme. This could be someone other than the compliance officer, perhaps another senior manager or possibly even someone independent of the business. This person should have access to all of the relevant information and records of the business and should be in a position to actively investigate the business' compliance processes. the compliance programme on an ongoing basis as a management activity effectively preventing infringements that they are being monitored for compliance competition law establish whether: are working supported by senior management compliance measures are appropriate, with the required results assessment are still valid function to actively investigate the business' compliance processes |