Product
The elements
Module A assesses a compliance program against the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs (September 2024). Module B, the Anti-Corruption add-on, adds questions keyed to the DOJ/SEC FCPA Resource Guide and to themes drawn from FCPA enforcement resolutions, and is mapped to ISO 37001.
There are 18 elements in both paths. Module B adds anti-corruption questions on top of them. Only item 3.3 is in Module B alone.
- 1High-Level Commitment
- 2Written Compliance Policy
- 3Risk-Based Procedures: Gifts, Hospitality, Travel, Donations and Sponsorships
- 4Internal Accounting Controls
- 5Risk Assessment In the demo
- 6Annual Review of Policies and Procedures
- 7Proper Oversight and Independence
- 8Training and Communication
- 9Guidance and Advice
- 10Confidential Reporting and Protection
- 11Investigation and Response
- 12Incentives and Enforcement
- 13Discipline and Remediation
- 14Third-Party Due Diligence and Oversight In the demo
- 15Third-Party Contract Provisions
- 16M&A Pre-Acquisition Due Diligence
- 17Post-Acquisition Integration
- 18Monitoring and Testing
How scoring works
- Fixed rules. Each answer scores 0 to 4. The rules are fixed. AI does not score your answers.
- A limit for serious gaps. Foundational gaps can limit the overall score, keeping important improvement needs visible.
- You choose the scope. You can assess only some elements. Unselected elements are left out of the score and their answers are kept. The overall score says how many elements it covers (18 elements in both paths), and the reports list the elements not assessed.
- One question at a time. The demo shows one question at a time and gives guidance when you ask for it.
- The method is explained in the app. You can read how the assessment and the scoring work under Help.
Try the demo.
The demo is open only by request. After we approve your request, we send you an access code.