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Perhaps, though, the best way to test for the effectiveness of the company’s

governance efforts is if every employee at any level of the organization knows

what the company expects of them, they know what the policies are, they

know where to find them, and have been trained on those relative to their

function. (Sounds like the perfect employee, doesn’t it?)

Hurdles to Instituting and Maintaining a Good Framework .....................

With any project that is worth doing, there are going to be a number of chal-

lenges and hurdles to overcome at implementation and throughout the life of

the initiative. Establishing and maintaining a good governance framework is

no different because there are a number of ways for a company to go astray.

In the next few sections, we give a few examples of issues to be considered.

78 Part I: Governance, Risk, and Compliance Demystified

The Open Compliance and Ethics Group

For those seeking a good resource to help them

get started on the journey toward GRC or for

those seeking to better hone their efforts, the

Open Compliance and Ethics Group (OCEG) pro-

vides quite a bit of information at its Web site

http://www.oceg.org. The OCEG is a nonprofit organi-

zation dedicated to helping companies align

their GRC efforts in order to drive business per-

formance and promote integrity.

To this end, the online magazine Compliance

Weekpublished a series of articles by Scott L.

Mitchell, chairman and CEO of the OCEG. These

articles are intended to help companies put the

goals of GRC into practice. (The series can be

found online at http://www.complianceweek.

com/index.cfm?fuseaction=Page.

viewPage&pageId=345.) Throughout the

11 part series, a number of best practices are

highlighted that relate directly to the gover-

nance function of GRC (many of these overlap

with the information provided above).

Here is a summary of a few of Mitchell’s points:

Corporate culture is a safety net for the

company facilitating information sharing

Talented individuals should drive the gover-

nance initiative and should occupy decision

making roles

The governing framework ensures that

objectives (strategic, operational, financial,

and compliance) can be achieved; prob-

lems being detected in a timely manner;

when detected the response is timely and

effective; and the framework complies with

internal and external regulations

Information should be able to easily reach

relevant external stakeholders

Technology should be used appropriately

Process and nomenclature should be ubiq-

uitous among the company’s units and

reflect industry norms

Valid tests and metrics should be in place to

validate the framework is functioning as

intended and detect issues