Fcpa Compliance Report

  Today I want to explore in some detail the first Objective in the COSO 2013 Framework-the Control Environment as a path to operationalize your compliance program. This Objective lays out five steps you can take to put the responsibility on function corporate disciplines to imbue compliance into the fabric of an organization.  A.        Control Environment  Rittenberg said this “sets the tone for the implantation and operation of all other components of internal control. It starts with the ethical commitment of senior management, oversight by those in governance, and a commitment to competent employees.” The five principles of the Control Environment object are as follows:  Principle 1 - The organization demonstrates a commitment to integrity and ethical values. Principle 2 - The board of directors demonstrates independence from management and exercises oversight of the development and performance of internal control. Principle 3 - Management establishes with board oversight, structures, reporting lines and