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The compliance framework needs to be contextualized so that it reflects not only the internal issues that affect the operation
of the organisation but it also the external environment. Here you must:
Establish what will be covered by the
compliance management system.
LEADERSHIP
The governing body and top management should demonstrate leadership and
commitment to the compliance management system. Management also must show
commitment by:
Establishing a compliance policy that is appropriate for the organisation and
communicated to all levels of the business.
PLANNING
Setting the right tone from the top, the governing body and leadership team
need to establish and uphold the organisations values.
EVALUATION
The framework needs to be monitored to ensure its effective,
current, and can identify instances where non-compliance
has occurred. Compliance indicators and reporting needs to
be established to help with this aspect. This includes:
A plan for continual monitoring should be established,
setting out monitoring processes, schedules, resources
and the information to be collected.
Conducting audits at least at planned intervals to provide
information on whether the compliance management
system is meeting its objective.
ISO 19600:2014
Compliance
Management
Systems
OPERATION
IMPROVEMENT
The compliance management system should drive continuous improvement in the
compliance program. This means:
When noncompliance occurs, the organization should take action to control and
correct it, and/or manage the consequences.
The organization should seek to continually improve the suitability, adequacy and
SUPPORT
The organisation needs to adequately support the
compliance management system. This includes:
Providing the resources needed for the establishment,
development, implementation, evaluation, maintenance
and continual improvement of the CMS.
All employees adhering to compliance requirements,
participate in training, report compliance concerns and
failures.
All staff should be provided with the necessary training
for them to undertake their duties while operating within
the framework.
Undertaking training when there are significant changes
or updates required or there have been a larger than
acceptable number of compliance breaches.
Raising awareness of the compliance policy and outlining
appropriate behaviour and the compliance culture of the
organisation.
Developing a common, published standard of behaviour
that is required throughout every area of the organization.
Determining the need for internal and external
communications relevant to the CMS.
The compliance framework needs to be documented,
available and updated as required.
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