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Annual reviews of policies and procedures
by Bailey Naples, CCEP
Director of Risk Management and Corporate Compliance with Berkshire Farm Center & Services for Youth
In this fast-paced, ever-changing regulation world, how is a compliance and ethics pro- fessional supposed to keep up? It can be a
daunting, if not impossible, task of staying up to
date on new regulations and changes to previously established policies. We must remember to
review even our most basic policies and procedures at least annually.
One option is to set up a policy review committee. If you are fortunate enough to
have a compliance committee already
established, you can tie this right into
your normal routine. The committee can
divide up the policies among members
to review, and then they’ll report back to
the committee at the next meeting.
A second option would be to set up a
similar timeline of review by yourself. The key is
to schedule the time and meet with yourself. Hold
yourself to the review time as though you were
meeting with a team.
When reviewing policies, begin by reading
the policy. Even if it’s a policy written by you,
I would strongly encourage you to read policies as though you are reviewing someone else’s
work. Think about the perspective of the reader;
they may not have the background knowledge
you have. If employees are coming to you often,
maybe the policy needs some clarification or
maybe the document could use an FAQ section.
After reading the policy, you should check
any hyperlinks and verify contact information.
It is easy for hyperlinks to become broken, even
ones within your company. While it is easier for
employees to have links within the policy and
procedures, it creates an additional responsibility for the policy owner to ensure they work.
While contact information likely won’t change
every year, turnover does happen and updates
do occur. Even the government changes phone
numbers and websites from time to time.
Next it is time to decide if you need to make
any minimal updates or if the policy needs
a complete overhaul. Minimal updates can
be done by the reviewer without a rollout to
employees. A complete overhaul may require
input from other teams and will definitely
require communication to employees.
Remember the important thing is to keep
policies and procedures up to date for the
employees. If the policies are outdated and
unreliable, it will be harder to get employees
to turn to them after all your hard work of
updating them. You will have to regenerate
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