In the case of a huge organization, how do they organize compliance management and educate all employees? Are there any good examples regarding (industry omitted) companies? In our company, each division has a lot of regulations and rules, but we are not centralized. I have the task to organize compliance management.

Mr. (name omitted),

Having been responsible for compliance management systems in a large company myself, I have given this topic a lot of thought. I believe the essential elements of a large corporate compliance management system are:

1. Survey – identify all the requirements that apply to the activity / organization (EPA regulations x, y, and z; OSHA regulations a, b, and c, etc.)

2. Organize – develop compliance programs that address the requirements identified during step 1 above. This includes forms, procedures, checklists, filing systems, and guidance manuals as appropriate.

3. Train – develop and conduct training programs for the people who will be required to understand and follow the applicable requirements.

4. Audit – conduct periodic audits of the operations and compliance programs to ensure that the compliance programs are working as desired.

5. Consult – have knowledgeable experts available to answer questions as they arise. These people typically reside at the headquarters level, or could be outside consultants (such as ourselves).

6. Monitor – since the rules are constantly changing, someone (normally the experts in step 5 above) must continually monitor the rules to ensure that the compliance programs are kept up to date. For example, the Department of Transportation rules for pipelines in the US are changed once a month on average. EPA and other agency rules change at least that often.

7. Influence – In the US, companies are given the opportunity to influence new and proposed rules. Most companies do not spend any time or effort in doing this, but they should. The major corporations are willing to spend the time and effort (and $s) to work with the regulatory agencies up-front to ensure that new rules are acceptable from the company's standpoint.

I hope this has been helpful. I have some specific examples of how to organize and conduct each of the steps identified above. We have developed the nationwide compliance manual for a large US pipeline system, and are currently working with other companies on their compliance programs. Please contact me if you need any assistance in developing a compliance process for your company – especially for facilities in the US.