Strong compliance systems and internal controls are essential for any USAID implementing partner. Various U.S. Government regulations require that recipients have effective standards and internal controls in place in order to ensure compliance with statutes, regulations, and the terms and conditions of Federal awards. How an implementing partner identifies, responds to, and prevents problems is what inspires trust in partner operations. This is generally achieved through an effective compliance and ethics program. 

An effective compliance and ethics program should exercise due diligence to prevent and detect misconduct and promote an organizational culture that encourages ethical conduct and a commitment to compliance. Some elements of an effective compliance program include: 

  • Standards and procedures to prevent and detect improper conduct;

  • Dedicated personnel for the overall responsibility for the compliance and ethics program; 

  • Training or dissemination of information to employees as appropriate related to standards and procedures;

  • Monitoring, evaluating, and auditing practices, policies, and procedures for compliance with the codes of conduct and other standards, policies, and procedures.

  • Internal reporting mechanism that allows employees to report incidents of improper conduct anonymously; 

  • Enforcement of the compliance and ethics program consistently throughout the organization through appropriate disciplinary measures; and 

  • The ability to take reasonable steps to respond appropriately to misconduct and to prevent further similar conduct, including making any necessary modifications to the organization’s compliance and ethics program.