Describe the essentials of an effective compliance program.

The elements of an Effective Compliance Program may be listed as under: High level company personnel who exercise effective oversight: The organization's governing body should be knowledgeable about the effective compliance program and should have oversight of it. The governing body should have the overall responsibility for the compliance program and shall ensure the effectiveness of it. Specific individuals shall have overall responsibility for the day to day operations of the compliance program. A Compliance Officer shall be designated by the organization's governing body, who shall periodically report to the higher level management/ governing body. The Compliance Officer should be given adequate resources with appropriate authority and direct access to the governing body. Written policies and procedures: The employees of the organization should be appraised about the legal requirements so that employees understand their obligations. The employees should be encouraged to report suspected fraud and other irregularities without fear. Training and education: The employees of the organization should be provided reasonable training to understand the organization's compliance programme and its policies and processes. Lines of communication: Information about the compliance program must be widely communicated at all levels of an organization. To enhance the effectiveness of the compliance program, the program must establish lines of communication whereby, employees and agents may seek guidance and report concerns, including the opportunity to report anonymously (such as a compliance hot line); There are assurances that there will be no retaliation for good faith reporting. Standards enforced through well-publicized disciplinary guidelines: The organization's compliance and ethics program should be promoted and enforced consistently through well-publicized guidelines that provide, incentives to support the compliance and ethics program, disciplinary measures for disobeying the law, the organization's policies, or the requirements of the compliance and ethics program. Internal compliance monitoring: The organization shall take reasonable steps, including monitoring and auditing, to, ensure that the organization's compliance and ethics program is followed, periodically evaluate the effectiveness of the organization's compliance program. Response to detected offenses and corrective action plans: After monitoring and auditing of the compliance program, the organization shall take reasonable steps to, respond appropriately to any violations of the law or policies to prevent future misconduct, modify and improve the organization's compliance and ethics program.