TheCorporateCounsel.net

July 18, 2023

Results of 2023 Compliance Risk Benchmarking Survey

Last fall, Dave blogged about corporate compliance programs, noting that the White House has identified corporate compliance as an Administration priority.  White & Case and KPMG recently released the results of a joint benchmarking survey of 201 senior decision-makers from more than 30 countries that has tons of helpful benchmarking data on corporate compliance programs. Not surprisingly, a number of recent hot topics — like third-party risk management and cybersecurity — got a lot of attention.

This page is packed with data-heavy infographics showing key insights at-a-glance. Here are some findings:

– Respondents reported that “use of third parties” was the greatest anti-corruption risk facing their company by far (59% versus the next highest risk “pressure to meet sales targets” at 36%)
– 43% reported that they annually review the content of the company’s anti-corruption compliance program, but only 28% tested its effectiveness annually (31% do not test their anti-corruption compliance programs at a regular cadence)
– Respondents ranked cybersecurity as top of their list of compliance priorities in the next 12 months
– Employees most often cited “fear of retaliation” as their top concern about using reporting mechanisms (55% for all respondents and 75% for respondents with > $50B in revenue)

The survey results show lots of opportunities for improvement and actionable items for companies to consider. Here are a few that stood out related to the key insights above:

– Regularly testing anti-corruption programs for effectiveness

– Measuring hotline awareness and effectiveness and addressing any employee concerns about hotline integrity

– Requiring third parties to complete anti-corruption training “to ensure third parties understand their obligations under applicable laws and relevant contract clauses, and to reinforce the consequences of non-compliance”

We have memos and other resources relevant to corporate compliance posted in our “Compliance Programs” Practice Area.

Meredith Ervine