CCEP Exam Dumps Study Guide
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Training based on risk assessment findings

This type of training aims to minimize the organization's legal exposure by addressing vulnerabilities identified through risk assessments.

FIRST step: Corrective action plan for misunderstanding harassment policy

Training should cover the harassment policy and its application in real-world scenarios, ensuring employees understand what constitutes harassment and their reporting obligations.

Guidance for developing a compliance program

The Federal Sentencing Guidelines provide a framework for developing compliance programs, offering a comprehensive set of principles and best practices.

Best outcome of a compliance and ethics program

An effective compliance and ethics program should mitigate risks by identifying, assessing, and addressing potential issues before they escalate.

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Price-fixing training: Which staff is MOST important?

Price-fixing is a serious antitrust violation and sales staff are most likely to engage in price discussions with customers.

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Compliance program: Policies regarding confidentiality

A compliance and ethics program should include policies regarding confidentiality to protect sensitive information and ensure ethical communication.

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Compliance Officer's FIRST action: Company with 250 stores

The Compliance and Ethics Officer should begin by identifying key risk areas to prioritize their efforts and develop a targeted approach.

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Compliance professional's BEST action: Supervisor's misconduct

The compliance and ethics professional should follow the program's requirements and ensure the company's legal counsel is aware of the situation.

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Compliance professional's FIRST action: Conflict between handbook and Code of Conduct

The compliance professional should first discuss the conflict with HR and legal counsel to determine the best course of action.

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Compliance professional's NEXT step: Code of Conduct review

Before consolidating revisions, the compliance professional should consult with the compliance committee to obtain input and consensus on the proposed changes.

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Most convincing demonstration of effective ethical standards

A company's termination of an executive who embezzled a small amount of money demonstrates a commitment to ethical standards by holding even high-level individuals accountable.

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Prohibiting payments to foreign officials

The Foreign Corrupt Practices Act (FCPA) prohibits companies from bribing foreign officials to secure business advantages. This policy will prevent violations of the FCPA.

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Compliance professional's FIRST action: Responding to a federal subpoena

The compliance professional should consult with legal counsel to understand the scope of the subpoena and advise employees on their obligations.

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Determining how a company prioritizes risk

Historical data on past incidents and violations can help identify recurring risk areas and prioritize those with the most significant impact.

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Employee's obligation to report misconduct

New employee orientation is the most appropriate time to discuss an employee's obligation to report misconduct, as it sets the foundation for a culture of compliance.

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Corporate employee allowed to be employed by an audit firm

The Sarbanes-Oxley Act restricts the employment of certain corporate employees by the corporation's audit firm during the year before an audit to ensure independence. The rule includes the Chief Accounting Officer.

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Department with the highest risk of non-compliance: Drug manufacturing

Transportation departments in drug manufacturing companies are at high risk for non-compliance due to strict regulations on handling and transportation of pharmaceuticals.

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Compliance professional's perception within the company

The compliance and ethics professional should be viewed as the company's ethical conscience, promoting ethical behavior and ensuring adherence to compliance standards.

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Audit finding violating Sarbanes-Oxley Act

The Sarbanes-Oxley Act prohibits an audit firm from providing bookkeeping services to a company they previously audited to ensure independence.

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Basic fiduciary duty of care principle

Under the Caremark principle, board members have a fiduciary duty to act in good faith and demonstrate reasonable care in managing the organization.

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Primary role of a compliance and ethics professional

A compliance and ethics professional's primary role is to promote a culture of compliance and ethical behavior throughout the organization, fostering a strong ethical foundation.

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Key component of a compliance and ethics program

On-going training is a key component of ensuring compliance and ethical behavior. Regular training helps reinforce standards and keep information current.

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Compliance professional's FIRST response: CFO's misconduct

The compliance professional's FIRST response should be to investigate the allegation to verify its validity.

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Structural compliance policy

A structural policy defines the overall framework and organization of the compliance program, outlining how it will operate.

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"Substantial authority personnel" in the Federal Sentencing Guidelines

Substantial authority personnel in the Federal Sentencing Guidelines refer to individuals with significant decision-making power, such as a purchasing supervisor who can influence purchasing decisions.

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Incorporating compliance into supervisor evaluations

Evaluation of supervisors should include assessment of their adherence to compliance and ethics standards, ensuring they uphold and enforce the program.

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Requirement for an organization's governing authority

The Federal Sentencing Guidelines require organizations to have a governing authority that provides reasonable oversight of the compliance and ethics program.

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Document to review with the supervisor: Employee complaint

The compliance and ethics professional should review the company's non-retaliation policy with the supervisor to ensure they understand the importance of protecting the employee who filed the complaint.

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Compliance professional's FIRST action: Anonymous hotline call

The compliance professional's FIRST action should be to verify the allegation of embezzlement by reviewing relevant financial records.

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Safeguard type: access controls, audit controls, integrity controls, and transmission security

Technical safeguards relate to policies that control access, audit, integrity, and security during transmission of electronic health information.

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Conflicts of interest for CEPs

Conflicts of interest can create divided loyalties for CEPs, potentially compromising their objectivity and effectiveness.

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Resource to ensure compliance and communication

An online reporting system provides a secure and confidential channel for employees to report misconduct, allowing for timely and anonymous reporting.

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When to ask for feedback on a training program

Feedback on the training program should be sought after the training is complete to assess its effectiveness and identify areas for improvement.

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"S" in the SMART format

The "S" in the SMART format stands for "Specific", meaning that the metrics should be clear, focused, and measurable.

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Uncommon name for an ethics hotline

Forced hotlines are not a common name for ethics hotlines.

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Goal of interviewing employees in an investigation

Truthful information is essential for conducting a thorough investigation. Interviewers must create a safe and neutral environment to encourage truthful answers.

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Truth about initial reports from a compliance investigation

Initial reports from a compliance investigation must be maintained in written form to preserve the integrity of the investigation and ensure proper recording of evidence.

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High-risk items in compliance

High-risk items require the most effort and resources to address, as they pose the greatest potential for negative consequences.

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Effective documentation for recognizing risk areas

External audit reports can highlight potential compliance risk areas by providing an independent perspective on an organization's practices.

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Study Notes

CCEP Exam Dumps Study Notes

  • Training based on risk assessment findings: The purpose is to reduce legal exposure and educate employees on relevant laws and regulations. It does not focus on educating the board or reducing insurance premiums.

  • Sexual Harassment Policy Corrective Action: The first step for a corrective action plan when an employee misunderstands the harassment policy is to provide education and training on the policy.

  • Compliance Program Development Guidance: Federal Sentencing Guidelines provide guidance for developing compliance programs. Sarbanes-Oxley Act, Security and Exchange Commission, and Office for Civil Rights are also relevant but not the sole guidance for program development.

  • Compliance and Ethics Program Outcome: The best outcome of a compliance and ethics program is mitigating risk. Identifying, prioritizing, and documenting risk are important aspects but not the optimal outcome.

  • Price-Fixing Training: Training on price-fixing is most significant for management, sales, and accounting staff.

  • Compliance and Ethics Program Components: A compliance and ethics program should include employee benefits handbooks, document retention guidelines, confidentiality policies, and a statement regarding the organizational culture.

  • New Compliance and Ethics Officer The first action of a new compliance and ethics officer is to conduct a risk assessment. Reviewing policies, performing an audit, or training employees, are all subsequent steps.

  • Supervisor Abuse/Harassment: When a supervisor is verbally abusive and sexually harassing, the compliance and ethics professional must report the findings to the CEO, with recommendations for discipline, despite advice to the contrary if there are litigation concerns.

  • Employee Handbook Conflict: If a conflict exists between a company's Code of Conduct and employee handbook (which is approved by the board), the compliance and ethics professional should schedule a meeting with HR, legal counsel, and the board to resolve the inconsistencies.

  • Code of Conduct Review: If a company's Code of Conduct has not been reviewed for two years and an expansion is proposed, the compliance and ethics professional should request guidance from the board of directors before completing the revisions. Comparing content with other organizations or using Federal Sentencing Guidelines as a rewriting basis are secondary steps.

  • Company Ethical Standards Demonstration: Effective ethical standards are best demonstrated through implementing an anonymous reporting system, terminating an executive for misconduct, or suspending/training an employee who failed to complete training. These actions demonstrate a commitment to ethics rather than just having a printed Code of Conduct.

Note: Additional topics covered in the provided text include details regarding Federal Subpoenas, compliance and ethics professional roles & responsibilities, legal frameworks, prioritization of risks, reporting misconduct, and corporate ethical standards. These are not exhaustive summaries of those topics, but key information relevant to those sections of the text.

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Prepare for the CCEP exam with this comprehensive study guide. It covers critical topics such as compliance training, harassment policy corrective actions, and guidance for developing compliance programs. Enhance your understanding and mitigate risks in your organization.

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