Amendments to the US Federal Sentencing Guidelines make it even more important for companies to step up their corporate ethics and compliance programs. The amendment adds subsection (f)(3)(C) to the guidelines, listing criteria companies must meet in order to consider being granted a fine reduction if found guilty of violating the guidelines. One of the items on the list calls for companies to promptly report the offense to government authorities – which is the focus of this article.
The Culpability Score
The US Sentencing Commission (USSC) hopes to encourage companies to take appropriate action upon discovery of criminal conduct within the workplace, and will give them credit for doing so. Here are the four criteria a company must meet before being considered for a fine reduction, according to the sentencing guidelines:
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- The individual or individuals with operational responsibility for the compliance and ethics program have direct reporting obligations to the organization’s governing authority or appropriate subgroup thereof.
- The compliance and ethics program detected the offense before discovery outside the organization or before such discovery was reasonably likely.
- The organization promptly reported the offense to the appropriate governmental authorities.
- No individual with operational responsibility for the compliance and ethics program participated in, condoned, or was willfully ignorant of the offense.
Reporting Solution: Case Management Software
When outlining the components of an effective ethics and compliance program, the sentencing guidelines state that once criminal conduct has been detected, a company shall take reasonable steps to respond appropriately to the criminal conduct and prevent similar conduct from occurring again in the future. i-Sight Case Management Software provides users with the tools they need to quickly and accurately report on incidents and investigations.
Here are three case management software features that help companies reduce reporting time and become aware of incidents sooner:
1. Case Entry
Cases can be entered into i-Sight using a variety of methods including:
- Integration with existing hotlines.
- Manual entry by a manager who was informed of misconduct.
- Anonymous and known reporting through an internal web form.
- Web forms posted on external company websites.
A hosted solution, like i-Sight, is always available and easy to access. 24/7 availability means that cases can be entered at all times, reducing the amount of time it takes to be made aware of workplace incidents and misconduct. Making case entry accessible allows employees to report incidents sooner. Web-based case entry allows employees to report incidents anonymously and from comfortable locations such as their own home. If they can only report misconduct while at work, they might be less likely to do so for fear of someone seeing- resulting in retaliation.
2. Automatic Alerts
Another i-Sight feature that results in faster reporting times is automatic alerts. i-Sight is configured to send alerts to identified individuals when new cases are entered. Each case can be manually or automatically assigned to an investigator to ensure that no cases are left behind. Rather than sitting in a stack of papers or relying on a supervisor to pass the complaint along, cases entered into i-Sight get immediate attention. Alerts are sent throughout the investigation process to keep you on task and draw attention back to cases that require immediate attention.
Once an investigation has been completed, i-Sight reduces the time spent preparing an investigation report to a click of a button. Many of our users tell us that before i-Sight, reporting on an investigation could take weeks; now, they spend only minutes or hours preparing reports. i-Sight keeps all case information in a centralized location, which means that all of the information you need for the report is in one spot. Our clients have also noticed that the quality and detail of the reports generated in i-Sight is much higher than manually prepared reports.