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Corporate Risk and Compliance: Theory and Practice
Section 6 . 1

Objectives and Discussion Questions

Kim Otte

We will consider how and when attorney client privilege attaches to the work of a compliance officer. In short, an attorney can direct work of a compliance officer to be conducted under privilege. Then we will study two more elements of an effective compliance program: communications/complaints and investigations. The OIG expects to see a communications channel (hotline, web intake) to intake employee concerns and a rigorous response and investigation process. Again, we will practically cover best pratice tips for executing on these elements and how to measure effectiveness.

Discussion Questions

1. Should a compliance officer put a program maturity model under attorney client privilege and why or why not?

2. Why might a corporation choose NOT to open an intermal investigation after receiving a government inquiry on a particular issue?

3. Should a compliance officer include "JD" on their corporate name badge?

4. Did your scandal include a hotline or investigation? what learnings?

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