Legally Speaking: Compliance Programs

By: Jill Miller, RSPA General Counsel

Every company is subject to laws, rules and regulations. Depending on the business you operate, the laws to which your company is subject varies. While publicly traded companies are required to maintain robust compliance programs, companies of all sizes and ownership structures should create and maintain compliance programs. An effective compliance program should be designed, implemented, and enforced with the goals of preventing, detecting, and correcting any inappropriate, criminal or illegal conduct.

At a minimum, every compliance program should contain the following components:

  • Written Policies and Procedures
  • Standards of Conduct
  • Oversight
  • Employee Training
  • Program Auditing
  • Corrective Action

The first step of developing a compliance program is to establish clearly defined policies, procedures and expectations for employees to follow. The company shall make the written compliance program available to all of its employees. Employees should receive training on all company policies and procedures. Your employees are in the best position to implement the company policies and procedures. Employees at all levels in your organization should have the opportunity to provide feedback to company leadership to enhance the compliance program and ensure that the policies and procedures established by the company are being adhered to by employees.

In order for a compliance program to be effective and relevant, employee training must be ongoing and continuous. The RSPA has established an online learning platform known as EXCELerate.  EXCELerate includes various courses on compliance training and allows individuals to self-select and track the courses they have completed. Utilizing this resource will help your company tackle one of the crucial elements of an effective compliance program, employee training. 

Establishing a robust compliance program makes good business sense and helps to protect your company’s brand and reputation while simultaneously ensuring your company complies with its obligations under state and federal law. As always, if you have any legal questions, the RSPA legal benefit is available to members, and I would be delighted to assist.  Stay safe.

RSPA Member-Only Benefit: Legal Assistance
The RSPA provides members with unlimited phone and email consultations with RSPA Legal Counsel Jill M. Miller along with access to legal templates. The legal counsel also meets one-on-one with members at RSPA events (RetailNOW and RSPA Inspire) and contributes to RSPA’s Connect magazine, Community Connection newsletter, Trusted Advisor podcast, and website. RSPA provides up-to-date legal guidance from an individual that knows the industry and the issues. RSPA members can connect with Miller by email at