Why a Compliance Program?

Present environment

• History of compliance and ethics in auto industry
• Expectations
• Benefits
• Dealer
• Financially
• Reputation
• Employees
• Customer
• Industry
• Internal and External Perception of a Compliance Culture
• End result - Culture of Compliance
• Infrastructure of a Compliance Program

High Level Oversight & Compliance Officer Responsibilities

• Board of Directors/CEO/Dealer Principal Oversight
• Oversight responsibilities
• Adequate Funding, Resources and Backing
• Compliance Officer
• Evaluate support ('Tone at the Top')
• Compliance culture of dealership
• Risk tolerance
• Risk appetite
• History of dealership compliance
• Ethical behavior of management
• Corporate Compliance Officer
• Skillset
• Self-assessment
• Resources
• Personal/professional development
• Compliance Committee
• Why need for check and balances?
• Building your compliance team
• Delegating Authority/Controls of Authority
• Definition
• Application
• Clear lines of authority and accountability
• New hire and HR vetting

Standards of Conduct/Culture of Compliance/Policies and Procedures

Code of Business Conduct, Values & Ethics

• Definition of compliance & ethics
• Behaviors
• What variables drive employee decision making?
• Compliance Policies & Procedures
• Establishing standards for a compliance culture
• Structural policies
• Substantive policies
• Policy audit
• How to Create Policy & Procedures
• Employee Handbook

Communication & Education

Employee Orientation and Staff Training

• Goal of training
• What is the expectation of the employee?
• How to communicate expectation
• What should be included?
• Checklist for adult learning best practices
• Assessment
• Reinforce expectations

Leadership Education

• Assess compliance knowledge and training needs

Consistent Communication

• Compliance topics
• Dealership compliance status
• Communication plan

Employee Performance Review component

• Partnership with Human Resources
• Effective lines of communication
• Two-way employee communication

Identification of Compliance Risks, Monitoring & Audits

Risk Assessment

• Review Internal Compliance Reporting Venues
• How to prioritize risks?
• Evaluate needs vs resources?

Monitoring

• Management by walking around/building trust
• Effective Compliance Checklists
• Reporting venues for employees
• Identification of Controls
• Offboarding (Exit Interviews)

Audits

• Internal audit
• GAP Analysis
• HR compliance audits
• Safety audits
• Regulation Audits
• Government Audit/Exam/Investigation
• Responding to Deficiencies Identified by Reporting or Audit

Reporting and Investigation

Reporting

• Investigation and Documentation
• Human Resources to manage the investigation
• What does the policy state?
• History or breach or violation?
• When is a 3rd party investigator required?
• When do I call the attorney?
• How to document for compliance needs

Enforcement and Discipline

Human Resources initiates consistent enforcement and discipline for violations

• Management in partnership with Human Resources address discipline and enforcement
• Understand the steps and expectations listed in the Progressive Discipline Policy
• History of similar infractions
• Consistent reinforcement ('Tone in the Middle')
• 3D's, Document, Document, Document

Response and Prevention

Identify Newly Identified Compliance Risks

• Complete a risk assessment of the infraction or breach
• Prioritize risks
• Address mitigation options
• Revise Policy and Procedures
• New or re-training needs
• Preservation of documents
• Lessons learned
• Monitoring expectations