The company must develop a monitoring plan to verify the effective implementation of the Integrity Program and enable the identification of flawed points that may lead to corrections and improvements. Continuous monitoring of the Program also allows the company to respond in a timely manner to any new risks that have arisen. Monitoring can be done by collecting and analyzing information from several sources, such as:
- Regular reports on the Integrity Program routines or related investigations;
- Trends verified in the complaints of the company's customers;
- Information obtained from the reporting channel;
- Reports from government regulatory or inspection agencies.
In addition to analyzing existing information, the company can, for example, test through interviews whether employees are aware of the company's values and policies, whether they follow the stipulated procedures and whether the training has brought practical results.
If the non-compliance with rules or the existence of flaws that are hindering the achievement of the expected results is identified, the company must take steps to remedy the problems encountered.
Depending on its characteristics, in addition to daily monitoring, the company may submit its policies and integrity measures to an audit process, in order to ensure that the measures established are effective and in accordance with the needs and particularities of the company.
Regardless of the specific measures adopted by the company, the monitoring process demands attention to some issues such as:
- Is the company adequately monitoring the application of policies related to its main areas of risk?
- Is the body responsible for the Integrity Program conducting the monitoring process objectively, with independence and autonomy in relation to the monitored areas?
- Does the monitoring include all areas of the company involved in the implementation of the Integrity Program?
- Have the results pointed out in previous audit processes, monitoring the Integrity Program and other review mechanisms been considered and corrected?
- How is the company responding to the issues identified during the monitoring process? Are action plans developed to correct the weaknesses found? Is there an area responsible for monitoring this action plan?