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4104 Felps Drive
Colleyville, Texas 76034
Seven Elements of a Compliance Seminar Program
November 2022 Compliance Seminar
Why a Compliance Program?
History of compliance and ethics in auto industry
Internal and External Perception of a Compliance Culture
End result - Culture of Compliance
Infrastructure of a Compliance Program
High Level Oversight & Compliance Officer Responsibilities
Board of Directors/CEO/Dealer Principal Oversight
Adequate Funding, Resources and Backing
Evaluate support ('Tone at the Top')
Compliance culture of dealership
History of dealership compliance
Ethical behavior of management
Corporate Compliance Officer
Why need for check and balances?
Building your compliance team
Delegating Authority/Controls of Authority
Clear lines of authority and accountability
New hire and HR vetting
Standards of Conduct/Culture of Compliance/Policies and Procedures
Code of Business Conduct, Values & Ethics
Definition of compliance & ethics
What variables drive employee decision making?
Compliance Policies & Procedures
Establishing standards for a compliance culture
How to Create Policy & Procedures
Communication & Education
Employee Orientation and Staff Training
Goal of training
What is the expectation of the employee?
How to communicate expectation
What should be included?
Checklist for adult learning best practices
Assess compliance knowledge and training needs
Dealership compliance status
Employee Performance Review component
Partnership with Human Resources
Effective lines of communication
Two-way employee communication
Identification of Compliance Risks, Monitoring & Audits
Review Internal Compliance Reporting Venues
How to prioritize risks?
Evaluate needs vs resources?
Management by walking around/building trust
Effective Compliance Checklists
Reporting venues for employees
Identification of Controls
Offboarding (Exit Interviews)
HR compliance audits
Responding to Deficiencies Identified by Reporting or Audit
Reporting and Investigation
Investigation and Documentation
Human Resources to manage the investigation
What does the policy state?
History or breach or violation?
When is a 3rd party investigator required?
When do I call the attorney?
How to document for compliance needs
Enforcement and Discipline
Human Resources initiates consistent enforcement and discipline for violations
Management in partnership with Human Resources address discipline and enforcement
Understand the steps and expectations listed in the Progressive Discipline Policy
History of similar infractions
Consistent reinforcement ('Tone in the Middle')
3D's, Document, Document, Document
Response and Prevention
Identify Newly Identified Compliance Risks
Complete a risk assessment of the infraction or breach
Address mitigation options
Revise Policy and Procedures
New or re-training needs
Preservation of documents
What to Expect
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