policy and procedure manualsThis is the third post in a series of articles discussing the importance of compliance for businesses in Olympia or Tacoma, Washington. The previous post addressed the importance of conducting an assessment to identify potential compliance risk areas. Compliance requirements are dependent upon many factors, including business activities, locations and status. Given the range of penalties for noncompliance, we recommend consulting with an experienced attorney to help minimize business risk. In this article, we will address another key element in a company’s compliance program – internal policies and procedures. If you need assistance, contact our office today to speak with a lawyer.

Once a company has identified the universe of laws, rules and regulations applicable to its business activities, it must effectively communicate those requirements to its employees. To do so, many companies develop and implement internal policies and procedures. These documents form the backbone of an effective compliance program. Internal policies and procedures explain the legal requirements and outline how an employee should act in order to comply with the rule. For example, many businesses have an internal Code of Conduct. This document may generally explain that all employees are expected to act within the law in the course of their employment. It may also, for instance, specifically instruct employees not to discriminate based on race, not to sexually harass other employees, or not to commit fraud against the company or third parties. Other common internal policies may include wage and hour guidelines, social media activity, or corporate gift giving or receiving. Each policy should be designed to prevent business activities from violating applicable law. Effective policies inform employees that violations could lead to disciplinary action and encourage reporting of violations by others.

If a violation should occur, enforcement authorities often review a company’s compliance program. A company’s overall commitment to compliance and vigilance with respect to enforcement of internal policies and procedures will likely be considered when assessing potential penalties. For this reason, it is imperative to carefully develop a program to communicate with and train employees about new or updated policies. Many companies conduct mandatory annual Code of Conduct training, tracking the participation of all employees. Others use software to distribute and track the receipt of policies and procedures. In addition, businesses should record violations and enforcement data as well as investigate reports of wrongdoing. Finally, it is important to regularly update policies and procedures to reflect changes in existing laws or new requirements.

Our firm has experience in preparing, reviewing and updating internal policies and procedures to help your business achieve its compliance objectives. If you need assistance, contact us today to speak with an Olympia business attorney. The firm also services the Thurston County cities of Lacey, Tumwater, and Yelm, the Pierce County cities of Tacoma, Puyallup, and Lakewood, the Lewis County cities of Centralia, and Chehalis, the King County cities of Seattle, Auburn, Bellevue, Burien, and Federal Way, as well as other areas in Washington, including Grays Harbor, Mason, Cowlitz, and Pacific Counties.

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