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How DOJ Compliance Guide Affects Employer Best Practices

Law360 (May 17, 2019, 12:08 PM EDT) -- On April 30, 2019, the Criminal Division of the U.S. Department of Justice released guidance titled “The Evaluation of Corporate Compliance Programs.”[1] This guidance sets forth a framework for designing, implementing and evaluating compliance programs, providing practical steps companies should take to ensure that their compliance programs are effective. It touches on the intersection of employment law, particularly with respect to encouraging employee reports of misconduct and preventing whistleblower retaliation; human resources best practices focused on creating appropriate incentive structures; and the management and minimization of risk related to compliance issues. The following analysis focuses on those aspects of the guidance....

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