Riordan Corporate Compliance Plan
June 11, 2012
Riordan Corporate Compliance Plan
Since its inception in 1991 Riordan Manufacturing has continued to grow and expand its operations internationally. The organization, wholly owned by Riordan Industries has over 550 employees across the United States and China, and as such, needs to be aware of the international laws which apply to their operations. Due to the size and net worth of Riordan manufacturing, an effective corporate compliance plan is required to ensure that all legislative requirements are met, and that the board and directors minimize risks to the organization, ...view middle of the document...
By identifying such events, the organization is more clearly able to identify opportunities, and ensure that risks are mitigated.
It is recommended that Riordan undertake annual risk assessments across the key areas of the business. Individual risk assessments should be completed in each of the following areas:
• Finance and Accounting
• Sales and Marketing
• Human Resources
The risk assessments should look for key risks to the systems and processes within each of these areas. Risks should be rated for likelihood and severity. Any risks rating above a three (on a five point rating scale) should have responses drafted for “avoiding, accepting, reducing or sharing the risk” (COSO, 2012, para.4). Riordan should ensure that all policies and procedures are up to date, and that these have been actively communicated with the workforce. Some policies may require employee sign off to ensure compliance. This should be discussed with legal counsel. This process should be repeated and audited annually.
Outside of the risk management process outlined above one of the key risks to Riordan relates to conflict of interest for employees or members of the board. Riordan mitigates this risk for board members through its Board Selection, Composition and Performance policies (Riordan Manufacturing, 2012) however a standard conflict of interest policy was not evident. Riordan Manufacturing should consider adding a definition of conflict of interest, as well as creating guidelines as to how such conflicts should be managed. The Board Composition and Performance Criteria (2012) states that “a director may, for personal or other reasons, such as a conflict of interest, submit his or her resignation to the Chairman of the Board” (para. 3). This reference to conflict of interest is the only one mentioned in the Riordan policies, however does not demonstrate what should be considered a conflict and therefore warrant the removal of a board member or employee from their position. Suggested wording for this policy is described below:
Conflict of Interest Policy
It is the policy of Riordan manufacturing that all employees should be free from conflicts of interest that could influence their loyalty or judgment to the company. Employees may take part in other activities outside their jobs but any potential conflict of interest must be disclosed to the Chairman of the Board. In the event that a potential conflict exists for the Chairman, the other board members should be made aware of that conflict. Employees should avoid accepting gifts, having financial interest in the business of a customer, supplier or competitor, or working directly or indirectly for a customer, supplier or competitor. Any conflicts not raised with the Chairman of the Board may lead to the removal of that employee from their position.
Creating a policy such as this protects the organization from legal risks...