Final answer:
An effective compliance program in FCPA matters includes dedicated resources for compliance, experienced personnel, and independence of compliance personnel from management.
Step-by-step explanation:
In FCPA matters, an effective compliance program aims to prevent and detect violations of the Foreign Corrupt Practices Act. Policies that would generally be considered effective include:
Dedicated resources for compliance of standards: This ensures that the necessary manpower, budget, and tools are allocated to effectively implement and maintain the compliance program.
Experienced personnel in compliance functions: Having knowledgeable individuals who understand the intricacies of compliance helps in identifying potential risks and designing effective controls.
Compliance personnel are independent of management: Independence ensures autonomy in carrying out compliance duties without undue influence or conflicts of interest.
Unclear reporting structure for compliance personnel: Having an unclear reporting structure can hinder the effectiveness of the compliance program, as it may lead to confusion, lack of accountability, and insufficient communication.