Integrating corporate social responsibility ("CSR")
into compliance structures and processes can be critical to
ensuring a company's CSR commitments are communicated and acted
upon. Only then can a company reap the intended benefits of a
voluntary commitment, whether those benefits are legal,
reputational, or operational. Ideally, CSR should be integrated
into training, learning, report, and auditing vertically and
horizontally across a company.
It is a mistake... to confuse the
aspirational nature of many CSR commitments for unattainable goals,
and a mistake to believe that those commitments cannot be broken
down into concrete deliverables, procedures, and policies for use
in achieving compliance. In fact, it is the process of converting a
CSR standard into tangible goals with an aspirational context, and
the dialogue and broad thinking that this process requires, which
can be the driver of successful implementation of the
In order to integrate aspirational commitments into concrete
compliance targets, companies should establish what those
commitments will require on a daily basis for the various business
units and departments. In the article, I suggest that companies
review the following steps as part of this exercise:
Articulate the standard.
Articulate the company commitment.
Identify existing complementary commitments or standards that
may impact implementation.
Create a working group to identify operational goals.
Identify relationships (e.g., contractor, supplier, JV partner,
host government) potentially impacted by implementation of
Articulate operational goals for each commitment.
Identify sources of information regarding risks and sources of
Identify key implementation steps for each standard.
Identify training, reporting and auditing requirements.
Identify Key Performance Indicators ("KPIs") for each
standard (group by group as appropriate).
Ultimately, transforming aspirational commitments into concrete
performance goals is fundamental to achieving real improvements in
the company's operations and the impacts of those operations on
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guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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stimates place the amount of money illegally "laundered" through
United States banks in the hundreds of billions of dollars each year.1
For more than five decades, the U.S. government has attacked money
laundering, in part, through anti-money laundering ("AML") disclosure,
monitoring, and reporting requirements placed on financial institutions.
On November 13, 2013, the Division of Corporate Finance at the Securities and Exchange Commission (SEC) updated its "Securities Act Rules Compliance and Disclosure Interpretations" (or CDIs) to provide 11 new interpretations relating to new Rule 506(c) and revised Rule 144A.