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Appointing a low level employee compliance officer or making a weak or ineffective compliance committee could point out that the organization is not really committed to compliance. Before outside counsel or auditors arrive on the scene, the group ought to announce the event of the corporate compliance program to staff, explaining the purpose of this system and the role of counsel and auditors. Another strategy can be to distribute the final Compliance Manual to all employees and then require each Department to assess its compliance points after which develop specific policies and tips addressing those points.
