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Objectives and Discussion Questions
Enforcement and discipline is our last element. We will consider internal enforcement and external enforcement. Both are important but too late. This element needs visibility and consistency to have credibility. Internally, HR is a core partner with compliance on this work. Externally, the compliance function is often engaged in the corrective action outlined in a settlement agreement.
Discussion Questions:
1. What did enforcement look like in your scandal?
2. Why might a corporation NOT want to agree to a Deferred Prosecution Agreement like we saw in the RXT case?
3. In the hypo, should the company adopt a "zero tolerance" stance? Why or why not?
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