Standards and Procedures Flashcards
7 cards from real CCEP practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 7 Standards and Procedures flashcards as text
A compliance team is conducting a periodic review of its conflict-of-interest policy. Which data source provides the MOST direct evidence of whether the policy is being applied?
Answer: Disclosure forms submitted by employees and the disposition records of reported conflicts
Disclosure forms and disposition records reveal actual employee behavior under the policy and whether identified conflicts are being managed appropriately.
Which scenario BEST illustrates a 'compensating control' when a primary procedural control cannot be implemented?
Answer: A company audits expense reports quarterly because it cannot afford real-time transaction monitoring
A compensating control substitutes for a primary control that is unavailable or impractical, providing alternative assurance that the risk is mitigated.
When a compliance officer identifies that a business unit is routinely circumventing a control by classifying expenditures as 'miscellaneous,' what is the MOST appropriate next step?
Answer: Conduct a root cause analysis to determine why the circumvention is occurring before redesigning the control
Root cause analysis identifies whether the control design, training, or culture is the underlying problem, enabling a solution that actually addresses the cause.
Which element of the OIG's seven elements of an effective compliance program specifically addresses the need for written standards?
Answer: Written policies, procedures, and standards of conduct
The OIG identifies written policies, procedures, and standards of conduct as the foundational element that codifies the compliance program's requirements.
A company adds a 'speak up' obligation to its code of conduct requiring employees to report suspected violations. What potential downside must the compliance team proactively address?
Answer: Fear of retaliation may prevent employees from fulfilling the obligation unless robust anti-retaliation protections are in place
A speak-up obligation is ineffective without credible anti-retaliation protections, because fear of reprisal is the primary barrier to employee reporting.
Which of the following BEST describes the concept of 'policy ownership' in a mature compliance program?
Answer: A designated individual or function is accountable for keeping a specific policy current, accurate, and implemented
Assigning a specific owner to each policy creates clear accountability for maintenance, updates, and ensuring the policy is understood and followed.
An organization's records retention policy specifies a 7-year retention period for financial records. During active litigation, what legal doctrine supersedes this policy and requires longer retention?
Answer: Litigation hold (legal hold)
A litigation hold suspends normal records retention schedules and requires preservation of potentially relevant documents for the duration of litigation or a reasonably foreseeable legal action.