CCEP Standards and Procedures 5

Question 1

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?

Accepted Answer

Disclosure forms submitted by employees and the disposition records of reported conflicts

Answer

Disclosure forms and disposition records reveal actual employee behavior under the policy and whether identified conflicts are being managed appropriately.

Question 2

Which scenario BEST illustrates a 'compensating control' when a primary procedural control cannot be implemented?

Accepted Answer

A company audits expense reports quarterly because it cannot afford real-time transaction monitoring

Answer

A compensating control substitutes for a primary control that is unavailable or impractical, providing alternative assurance that the risk is mitigated.

Question 3

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?

Accepted Answer

Conduct a root cause analysis to determine why the circumvention is occurring before redesigning the control

Answer

Root cause analysis identifies whether the control design, training, or culture is the underlying problem, enabling a solution that actually addresses the cause.

Question 4

Which element of the OIG's seven elements of an effective compliance program specifically addresses the need for written standards?

Accepted Answer

Written policies, procedures, and standards of conduct

Answer

The OIG identifies written policies, procedures, and standards of conduct as the foundational element that codifies the compliance program's requirements.

Question 5

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?

Accepted Answer

Fear of retaliation may prevent employees from fulfilling the obligation unless robust anti-retaliation protections are in place

Answer

A speak-up obligation is ineffective without credible anti-retaliation protections, because fear of reprisal is the primary barrier to employee reporting.

(CCEP) Certified Compliance and Ethics Professional Practice Test

(CCEP) Certified Compliance and Ethics Professional Practice Test

CCEP Standards and Procedures 5