Riordan Corporate Compliance Plan

Riordan Corporate Compliance Plan University of Phoenix Introduction Riordan Manufacturing was founded in 1991 with patent awards from processing polymers into strong plastic substrates (University of Phoenix, 2003). In Albany, Georgia, the organization’s first manufacturing plant saw growth through the production of plastic beverage containers in 1993. Today, Riordan Manufacturing has custom plastic parts produced in Pontiac, Michigan as well as plastic fan parts in Hangzhou, China. Aircraft and auto part manufacturers are some of Riordan’s clientele.

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Riordan also has numerous manufacturing contracts with the Department of Defense, beverage makers and bottlers, and appliance manufacturers (University of Phoenix, 2003). Corporate Compliance Overview Heads of Riordan Manufacturing created a Corporate Compliance Plan tailored specifically to plastic designs. Ethical standards guide Riordan’s business practices and its employee expectations. In it, management is expected to lead with integrity and to promote an environment where compliance and ethical business practices are above reproach.

Riordan’s corporate compliance plan outlines its mission: to ensure awareness and compliance with applicable laws, rules and regulations to the workforce, including federal and state programs, fraud, waste and abuse, ethics, privacy and security requirements and corporate governance. The purpose of the compliance plan describes the importance of internal controls and submits a proposal to mitigate enterprise risks by applying sound principles and recommendations found in the Committee of Sponsoring Organization of the Treadway Commission (COSO). Code of Business Conduct and Ethics

The Code of Business Conduct and Ethics informs Riordan Manufacturing directors, executive officers, and employees of organizational ethical expectations. Honesty and Integrity is Riordan defines the organization’s dynamic business environment through honesty and integrity. Corporate integrity is a commitment pursued in open, honest and fair dealings with all its customers insuring the highest customer satisfaction from its consumer goods and services. Conduct Standards Riordan employees are responsible to make certain the integrity and accountability protection of all documents.

All documentation is considered proprietary and confidential. All employees are encouraged and expected to report any violation of this policy to his immediate supervisor. Use of Proprietary Assets Employees of Riordan are required to protect organizational resources. Company assets include office supply and equipment and property not for personal use (Community Services, 2007). Any misuse of organization funds, information, equipment, or other assets can result in appropriate disciplinary action or dismissal. Employees will ensure that organization assets are for official business use only.

Corporate Image As stated above, all transactions and business dealings with customers will adhere to established ethical standards. All business will take place with the customer in mind. Any transaction brought to the attention of management by customers deemed unethical or outside the business’ norm will be reviewed for implication. Legal Obligations and Compliance Market share liability (enterprise liability) is held jointly liable for action on the basis on being a part of a shared enterprise: Riordan Manufacturing, DBA Riordan Industries.

Quality Control ensures products are free from design and manufacturing defects. State and federal regulation determine warranty and consumer protection requirement guidelines. Riordan Manufacturing conducts business globally and is, therefore, responsible to adhere to the rules and principles of the host country in accordance with International Law and any local jurisdiction. Business Continuation A large portion of management’s responsibility is to identify and mitigate uncertain risks to business operations globally.

Enterprise risk management (ERM) is the approach assisting management in identifying and managing uncertainties and in attaining positive risk intents. ERM efforts are on developing a strategy to introduce cognizant internal risk control throughout the organization. This structure is an effort by the COSO to effect responsibility on executives and directors through informed organizational procedures and processes that assist these individuals in reporting organizational management metrics (Applegate, 1999). Prevention Management

The COSO enterprise risk management structure recognizes an organization’s need to infuse risk management into strategic objectives and the organization’s culture. To protect against unplanned or unforeseen risk, all layers of Riordan are exercised and evaluated on how the response protects assets and personnel. Entities within Riordan Manufacturing that fail to comply with local, state or federal governmental regulations expose the organization to regulatory risks and liability that impact assets, earnings, and most important, Riordan’s reputation as a civic supporter.

Carefully designed preventive measures within Riordan’s manufacturing model provide internal controls for day to day business operations. These reduce, limit, and eliminate exposure to tort liability, fines and criminal penalties (Limtiaco, 2009). Riordan Executives and Directors will heed the following necessary steps found in Mr. Dennis Applegate’s 1999 submission to the COSO website, www. coso. org; “Struggling to incorporate the COSO recommendations into your audit process? Here’s one audit shop’s winning strategy… ” in implementing ERM: Develop a local risk management strategy.

Determine corporate philosophy and delegate risk controls appropriately. Perform of risk assessments to determine total versus return on investment. Identify through practice, risk response communication and analyze risk results. Continue review and oversight to ensure compliance from management. Executives and Directors of Riordan Manufacturing are expected to reprioritize personal interests and align local corporate control and risk management as a priority. Clean Air and Water Act Plastics are universal to industries and products around the globe.

Production of plastics are affected by many regulations across the world (Murner, 2009). Riordan Manufacturing’s responsibility is to ensure full compliance of the Clean Air and Water Act by responding immediately to violation(s) and monitor progress of the violation to preclude future noncompliance. The responsible Director must review, update and follow-up on issues in regard to environmental violations to ensure full compliance of the law and to prevent future negative impact and public media attention. Occupational Safety and Health Administration

Compliance of OSHA regulations will reduce work-related injuries, illnesses and death through proper annual workplace safety inspection and review. Reported violations are addressed immediately by the responsible management official. OSHA information concerning the workplace rights are posted on all employee bulletin boards and made available to all employees. Any questions that may arise need to be addressed to human resources. Arbitration Dispute Resolution (ADR) provides an opportunity to resolve any issue to and minimize the possibility of litigation.

Mediation through “peer review” processes fall within this category of dispute resolution and provides parties engaged a different option to pursue. Consumer disputes will be resolved through Product Support Division and elevated using the appropriate chain of command to the Chief Legal Counsel for review. The course of action will be determined then, thus minimizing negative impact of such a dispute. Federal Trade Commission Act Riordan Manufacturing is committed to providing accurate information on all products sold to a consumer which meets state and federal guidelines.

All products carry an express warranty for the quality, abilities, or performance of the product as provided in the Uniform Commercial Code (Jennings, 2006). Executives must ensure full compliance of the act to avoid any product liability issues and reduce the possibility of negligence, intentional tort or strict tort liability. Report any legal actions through the Corporate Compliance Officer to the Chief Legal Counsel who overseas all legal matters for Riordan Manufacturing. Intellectual Property Rights Intellectual property consists of Riordan Manufacturing trademarks, copyrights, patents, and trade secrets.

Trademarks are defined under the Lanham Act of 1976 and are defined as a word, name, symbol or other designation that is representative of the organization from others (Jennings, 2006). Trademark or patent infringement is likely to occur abroad, presumably in China where our manufacturing plant is operating. The VP International Operations and Director Plan Operations management must be aware of the competitors in the area to alert Senior Executives of potential competitor’s infringement of Riordan Manufacturing. Report any instances of intellectual property violations to the Chief Legal Counsel for further review.

Executive management will review the case and proceed with appropriate direction. Management and Control Riordan Manufacturing is a profit corporation with unlimited duration, free transferability of interest, limited liability for shareholders/owners, continuity, and centralized management (Jennings, 2006). In accordance with the Model Business Corporation Act, Riordan Manufacturing will abide by the principles of corporate law within the states where Riordan Manufacturing plants are established. Riordan Manufacturing will comply with the state and federal guidelines as established for the organization.

Corporate Governance Riordan Executive Managers and Directors are involved with the responsibility to ensure compliance with the organization strategy, policies and guidelines and accountability to the stakeholders in the organization. Issues requiring corporate governance principles include: Internal controls, oversight and management of risk, oversight of the entity’s financial statements, and review of the compensation arrangements for the CEO and other executives. Corporate governance must go beyond the duties and responsibilities; it must go beyond the law.

It must strive to meet well defined, written objectives that are fair, efficient and transparent. Financial reporting is a vital component necessary for corporate governance to function effectively. Executive Management should expect the financial information to be in compliance with statutory and ethical obligations as prepared by accountants and auditors competence. Compliance Officer The Corporate Compliance Officer will be responsible to oversee and direct the Compliance Plan. The Corporate Compliance Officer will report to the President/CEO and Chief Operating Officer.

The Corporate Compliance Officer is responsible to report significant and pertinent information through the appropriate executive channels for review and final resolution. Reporting Suspected or Known Violations All Riordan Manufacturers employees are responsible to report immediately any infringement of the Code of Business Conduct and Ethics. Riordan’s Corporate Compliance Plan is developed to allow the employee the opportunity and responsibility to report any activity by division representative that convincingly show to go against applicable laws, regulations, and policy or Corporate Compliance requirements.

Notice concerning possible litigation against Riordan or alleged violations of law by Riordan is required to report to the senior leadership. Riordan encourages employees to share his or her questions, complaints, suggestions or recommendations to the organizational leaders within the division. Investigations and Corrective Action Any and all alleged violations are to be investigated immediately or the Corporate Compliance Officer will administer the action to be taken. Investigations will be treated in confidence to the level that is consistent with Riordan interests and legal requirement (Community Services, 2007).

Suspected violations will be investigated and documented for submission to the President/CEO and Chief Operating Officer for review (Community Services, 2007). If the investigation indicates from the results that corrective action is required, Riordan will make a decision on a suitable course of action to acquire, to include: discipline, dismissal and possible lawful measures. The investigation may require an outside source to assist in the inquiry of the inquisition, if deemed necessary. Conclusion The recommendations by COSO provide a comprehensive reference for Riordan to develop an effective ERM program with strong internal controls.

These controls maintain compliance and establish adequate checks and balances. Riordan Manufacturing takes a proactive approach in Corporate Compliance by implementing its own enterprise risk management approach to comply with state and federal mandates and ensure Riordan Mfg. establishes measures and internal controls to prevent, identify, and manage risks appropriately. A productive and responsible organization like Riordan Manufacturing reflects a positive image to the public that will bring credit to the contribution of the goods and services provided by the organization as a whole (Limtiaco, 2009).

A commitment to comply with the items on this document is essential to a successful corporate compliance charter. References Applegate, Dennis. (1999). Struggling to incorporate the COSO recommendations into your audit process? Here’s one audit shop’s winning strategy… COSO. Retrieved June 17, 2009, from http://www. coso. org/audit_shop. htm Community Services (2007). Corporate Compliance Plan. Retrieved June 20, 2009, from http://www. csdd. info/Institute of Business Ethics (2003). Developing a code of business ethics. Retrieved March 11, 2009, from http://www. ibe. rg. uk/developingsumm. htm Jennings, M. M. , (2006). Business it’s legal, ethical, and global environment. Managing disputes. Available from the University of Phoenix eBook Collection database. Murner, Christine. (2009). Plastics, Electronics and the Environment: How New Global Regulations Affect Materials Choices. Plastics Technology. Retrieved June 18, 2009, from http://www. ptonline. com/articles/200610fa2. html University of Phoenix. (2003). Riordan Manufacturing [Computer Software]. Retrieved June 19, 2009, from University of Phoenix, Simulation, Law531-Business Law.

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