corporate compliance plan bev

Running head: RIORDAN CORPORATE COMPLIANCE PLAN

1

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Riordan Corporate Compliance Plan

RIORDAN CORPORATE COMPLIANCE PLAN 2

Beverly Mahone

LAW/531

March 11, 2013

Joseph Sette

Date: March 11, 2013

Subject: Riordan Corporate Compliance Plan

To: Riordan Executive Officers and Directors

[A job title is not capitalized unless it is the first word in a sentence or associated

with the name of a person or institution, e.g., Certified Public Accountant John

Doe. If not, it is just a label, such as auto mechanic, nuclear physicist, fry cook,


brain surgeon, professor, etc.] I. Organization Overview

In 1991, after obtaining several patents from processing polymers into high tensile strength

plastic substrates, Dr. Riordan founded Riordan Manufacturing (University of Phoenix, 2013).

In 1993, Riordan Manufacturing, Inc expanded into the production of plastic beverage containers

at the organization’s first manufacturing plant in Albany, GA. Riordan Manufacturing now

["Now" is a difficult word. Because this is being read some time after you wrote it, "now"

is ambiguous--do you mean at the time you were writing? When was that? If you mean "as

of the present time" (Hawaii is now a state), you can leave out "now." If the time or date is

important, fill it in. If the essay is in the past tense, instead of "now," use "then"] has

custom plastic parts produced in Pontiac, Michigan [insert comma] ; plastic fan parts in

Hangzhou, China, as-well-as the plant in Albany, GA. Riordan’s customers include aircraft

manufacturers, automotive parts manufacturers, the Department of Defense, beverage makers

and [in academic writing, if this is a series, place a comma before the final conjunction

(and)] bottlers, and appliance manufacturers (University of Phoenix, 2013).

II. Corporate Compliance Overview

A Corporate Compliance Plan has been created [The passive voice is a form of "be" (been)

and a participle (created). Over-use of the passive voice can make paragraphs officious and

tedious to read. Prefer the active voice. For example, passive voice = The paper was

completed on time. Active voice = the student completed the paper on time. See Center for

Writing Excellence > Tutorials & Guides > Grammar & Writing Guides > Active &

passive voice] by Riordan Manufacturing customizing to the organization’s specialized field of

plastic designs. Riordan has made a commitment to manage and operate the organization

programs with the utmost degree of business, and ethical, and moral principles. Employee


expectations are to contribute to the business functions of the organization with integrity and

ethical standards. To achieve these standards management contributes by demonstrating

leadership, integrity, and being [Remove comma (if the following is not an independent

clause or last element in a series)] [Doctoral rule (but good advice for any academic

writer)--If not a noun (as in "human being"), the word "Being" is hard to imagine; it

means "existing." Try to rewrite this without using "being"--with action words like

"attending," "working," "living," "experiencing," simply "as"--or even removing "being"

completely] a role model to employees which [Check word usage--If this word refers to a

human being, people are never "that" or "which," they are "who"] promotes an

environment in which compliance and ethical business practices are expected [Passive voice ] .

The purpose of this corporate compliance plan is to detail the importance of internal controls and

present a proposal to minimize enterprise risks by applying the principles and or ["and or" is an

awkward construction, a shortcut appropriate in a legal document, not in academic

writing] recommendations of the Committee of Sponsoring Organization of the Treadway

Commission (COSO). Recommended Changes to Riordan's Corporate Compliance Plan are as

follows.

Alternative Dispute Resolution Clause

a) Any individual or individuals who fail to adhere to the company's compliance plan will be

subject to disciplinary action. These disciplinary actions will be written and verbal warnings,

suspension and [in academic writing, if this is a series, place a comma before the final

conjunction (and)] [Insert a comma before this word if this is the last in a list of more than

two -- or if it begins a new clause] can include termination. The level of violation will

determine which action type will be enforced [Passive voice ] . By enforcing this clause, the


company will make sure employees are aware of the importance in following the company's

compliance plan. These clauses are intended [Passive voice ] to increase productivity and will

allow the company meets compliance obligations.

b) To date Lowell Bradford acts as the company's legal advisor, Bradford is responsible for

answering legal inquiries and has the capability to make legal decisions on behalf of the

company (University of Phoenix 2013 [Place comma after author name] ). Riordan

Manufacturing also counts with the legal supports of a law firm they feel comfortable working

with when additional legal advice is necessary. The legal firm is paid on a monthly basis and no

carry forward of retainers are allowed, thus even if their services are not needed. If at any point

Riordan uses the legal firm's services in excess of their agreement then [consider removing

"then"] Riordan is subject to pay additional fees.

c) Based on Mr. [Avoid using salutatory titles] Bradford's experience as Chief Legal Counsel,

Riordan manufacturing should consider eliminating the law firm services., Mr. Bradford is

experienced [Passive voice ] enough to provide legal advice, and he is also qualified to answer

any legal questions and approve contracts. By canceling the law firm services and allowing Mr.

Bradford to take on more responsibility, Riordan will not only benefit by making their personnel

more experienced but will also save money.

Enterprise Liability

a) Mr. Bradford will ensure the corporation is doing everything that is [Wordiness: see if

you can remove "that" or "that is"] necessary to protect themselves against the

possibility of lawsuits.

b) All [Writing suggestion: "All" or "all of" used as an intensifier very often can be

removed with no loss of meaning] employee handbooks and or [Do not use and or]


any other type of legal document should be reviewed [Passive voice ] and updated where

necessary. These handbooks will be distributed [Passive voice ] to all employees and

each employee will sign and acknowledgement of receipt confirming that they [Check

pronoun agreement--if "they" refers to "each employee" (or a singular subject), it

should be singular, too (he or she) and perhaps require adjusting the following verb]

have read and understand the entirety of every document. The company should also

verify that background checks are being done [Passive voice ] to all employees who are

hired [Passive voice ] .

c) Riordan Manufacturing will enforce a policy that will allow employees to come

forward with issues without being afraid of losing their job. These steps will in a way

protect the company against torts committed by its employees.

Product Liability in Different Areas of the Riordan Manufacturing Organization

As mentioned before, Riordan Manufacturing produces plastics for of automotive parts

manufacturers, aircraft manufacturers, the Department of Defense, beverage makers, and

appliance manufactures. [Move the period to follow the citation] (University of

Phoenix) As part of its mission statement, Riordan mentions keeping long-term

relationships by maintaining quality controls, innovative solutions, reasonable pricing

and [in academic writing, if this is a series, place a comma before the final

conjunction (and)] [Insert a comma before this word if this is the last in a list of

more than two -- or if it begins a new clause] good customer service. In order to

[Writing suggestion--the meaning will be the same (and less wordy) by removing "in

order"] ensure the company is keeping its promises, Riordan needs to ensure

[Misplaced modifier: the phrase beginning with "In" does not identify who or what


is " ensure the company is keeping its promises." The only possible choice is what

follows-- Riordan needs to ensure. In other words, you are saying that Riordan

needs to ensure is or are trying to ensure the company is keeping its promises. Fill

in who or what is performing the action.] that its products are being produced [Passive

voice ] in a timely manner, that [Remove comma before "that" preceding a

restrictive phrase (otherwise replace "that" with "which")] the products are of good

quality, and that new systems are integrated [Passive voice ] on a regular basis to help

with efficiency.

Finance

Currently, the San Jose, Michigan, and Georgia offices have all purchased different

software applications that run on different operating systems (University of Phoenix). As

a result it is difficult for the company to consolidate its information for financial

statements without re-entering data. This process can be labor intensive delaying the

consolidated close by 15-20 days. These delays make it difficult to comply with

Sarbanes-Oxley (SOX) regulations. It also allows for [This is a phrasal verb, two words

that together mean something different from their individual definitions--looking up

each word in the dictionary would not produce the meaning, which could cause

misinterpretation in an international business communication. Try different

wording, such as simply "allows" or a form of "provides," "permits," etc.]

additional human error.

In order to [Writing suggestion--the meaning will be the same (and less wordy) by

removing "in order"] fix this problem, the systems at each [Misplaced modifier: the

phrase beginning with "In" does not identify who or what is " fix this problem."


The only possible choice is what follows-- the systems at each. In other words, you

are saying that the systems at each is or are trying to fix this problem. Fill in who

or what is performing the action.] office should be unified [Passive voice ] so that

each office is using compatible software and operating systems. All source codes should

be included [Passive voice ] and licensed as well. Unification will reduce the manpower

needed to produce financial statements since [Check word choice--"Since" is more

precise in referring to time (meaning "after that"); otherwise use "because"] all

information will be exportable instead of needing to be reentered [Passive voice ]

manually. Exporting the data reduces the possibility of human error. Reports that will

allow employees to double check the information will also be available. In order to

[Writing suggestion--the meaning will be the same (and less wordy) by removing "in

order"] meet their SOX deadlines, Riordan should look into [Misplaced modifier: the

phrase beginning with "In" does not identify who or what is " meet their SOX

deadlines." The only possible choice is what follows-- Riordan should look into. In

other words, you are saying that Riordan should look into is or are trying to meet

their SOX deadlines. Fill in who or what is performing the action.] purchasing a

compliance auditing software program such as Compliance11 Supervisory Suite

(Compliance11, 2009). The program provides a cost effective [As an adjective, these

two words are hyphenated] plan for regulatory compliance personnel and compliance

management.

Human Resources [Check capitalization: This is not capitalized unless part of a

proper noun (company or brand name)]

The Human Resource [A "human resource" is a single person; written in plural,


"human resources" is the personnel office ] department is in need of some updated

software as well. The current software was installed [Passive voice ] in 1992 and only

holds a limited amount of information (University of Phoenix). Spreadsheets are being

used [Passive voice ] to track resumes and application status and information related to

compensation decisions. Workman's compensation is being tracked [Passive voice ] by

an outside company and employee relations specialists are tracking information about

complaints, grievances, sexual harassment complaints and [Insert a comma before this

word if this is the last in a list of more than two -- or if it begins a new clause] other

employee issues. Security and confidentiality could become a concern as a result and

possible lawsuits in regards [Use "regard" ("regards" are feelings of affection)] to

employee confidentiality could arise.

The Human Resource [human resources] department needs to invest in a software

program that will allow the company to be able to [Wordiness: Remove "be able to";

the sentence will read more smoothly without it] process all of this information in one

system. The information would be more secure and access to each area could be

password protected [Passive voice ] . The password protection will reduce the possibility

of employee confidentiality violations. Updating the software will eliminate human error,

the possibility of corrupted spreadsheets, and the ability for the company to ensure that

all information is accurate. Also the use of the outside company reporting workman's

compensation claims will be eliminated [Passive voice ] which [Use "that" for a

restrictive phrase (or place a comma before "which")] will save the company money.

Sales

The Sales and Marketing department has incorporated a system to electronically record


[Doctoral rule (but good advice for any academic writer)--avoid a split infinitive;

consider placing the adverb (electronically) before or after the infinitive (to

record )--try "electronically to record " or "to record electronically" (or place

"electronically" later in the sentence)] its sales data (University of Phoenix). In the past

all tracking was done [Passive voice ] using a pen and pencil. The electronic system

allows the tracking of orders, delivery, product pricing, and volume of sales can be

tracked [Passive voice ] to ensure Riordan is profitable in the area of sales. However, the

sales database is different for each sales team member. Some use pen and pencil and

some use sales management software. Riordan will incorporate sales software that can be

used [Passive voice ] by all sales team employees. The system should be compatible

with the electronic system that records the sales data. Each team member will be able to

enter their [Check pronoun agreement--if "their" refers to "member" (or a singular

subject), it should be singular, too (his or her)] information as well, thereby allowing

Riordan and the sales team to be able to [Wordiness: Remove "be able to"; the

sentence will read more smoothly without it] analyze the sales data and to make

educated decisions toward productivity and profitability. Also, [Remove comma (unless

introducing a nonrestrictive phrase)] the system will be less time consuming [As an

adjective, these two words are hyphenated] for employees and reduce the possibility of

human error.

There has also been market research conducted, marketing plans creating and Riordan

has earned various design awards and governmental contracts. These will also be

included [Passive voice ] in the sales software as a reference for future business. Riordan

will be able to review these documents to analyze what methods and practices have


worked in the past ["in the past" is redundant (When else could this have occurred?)]

and to increase sales in the future [Redundancy: "in the future" is repetitive--"will

be" means in the future] .

Operations

The Georgia office produces many small orders at a time due to the fact that [Wordiness:

avoid "due to the fact that" in academic or business writing. Use simply "because"]

they are unsure of their sales outcome for the year (University of Phoenix). Safety stocks

of popular models are kept to ensure the branch can meet its deadlines. On-time

deliveries are at 96% which [Use "that" for a restrictive phrase (or place a comma

before "which")] is acceptable, but the cost for shipping these small orders can become

quite costly. Riordan should look into using a different shipping company to save on cost.

A company that also delivers internationally is another thing to consider. If Riordan finds

a company that is able to [Wordiness--"is able to" means simply "can"] accommodate

timely deliveries for all offices, including China, they might [Check word choice: Use

"might" to indicate an uncertain possibility. Use "may" for a possibility almost a

sure thing] be able to negotiate a cheaper rate due to [Check word usage: This phrase

is most accurate in referring to something owed ($5 due) or an arrival time (due at

6:00)--try "because" or "because of"] the increased amount of business they would be

generating.

The Michigan facility manufactures [Misspelling--manufacturers] customized plastic

parts, making productivity difficult (University of Phoenix). The customers each have

their own requests and therefore dies need to be created [Passive voice ] to

accommodate these requests. All parts are ordered [Passive voice ] before these products


are created [Passive voice ] . Riordan should analyze their sales data to see which

customers keep coming back. Molds of the customers' orders should be kept to help

speed up ["expedite" or "accelerate" may be more appropriate in academic

writing.] productivity. Riordan may even receive increased orders as a result, since

[Check word choice--"Since" is more precise in referring to time (meaning "after

that"); otherwise use "because"] those customers will realize the extra effort Riordan is

applying to their satisfaction.

Fan parts are currently being produced [Passive voice ] in China. The current issue at

this time is that delivery of these parts is only at 93% which [Use "that" for a

restrictive phrase (or place a comma before "which")] is not up to [Colloquialism--if

"is up to" is intended to mean "the responsibility of," this phrase might not be

universally understood--avoid it in academic or international business writing]

Riordan's standards (University of Phoenix). The current shipping company being used

[Passive voice ] is similar to Fed-Ex, but is [Remove comma (if the following is not an

independent clause or last element in a series)] less expensive. However, it does not

appear that the shipping company is meeting deadlines. The China entity should consider

using a different shipping company that guarantees timely deliveries.

International Law

Riordan also needs to be sure that the employees who are [Writing suggestion: rewrite

the sentence to remove "who are"] communicating with China have a good

understanding of the customs and cultures practiced in China. Riordan may want to

consider sending these employees to a culture awareness class that will educate them on

the dos and don't [Contractions are inappropriate in academic writing--write it out] s


in China. Frequent reminders of the practices in China will ensure that employees are not

offending the employees of that entity and ensure smooth business transactions.

Tangible and Intellectual Property

Riordan Manufacturing should ensure that all patents and trademarks of their products are

up to date. The bottles, fans, automotive parts and [in academic writing, if this is a

series, place a comma before the final conjunction (and)] other products produced by

Riordan are all examples of items that need patents. Also, [Remove comma (unless

introducing a nonrestrictive phrase)] Riordan should ensure that their designs for these

products are secure so that there is no chance of duplication from another company.

Employees that [Check word usage--If this word refers to a human being, people are

never "that" or "which," they are "who"] are [Writing suggestion: rewrite the

sentence to remove "that are"] involved [Passive voice ] in designing these products

will be required [Passive voice ] to sign disclosure documents that ensure they will not

release this information to other companies.

China customizes fans for many of their customers. Riordan needs to ensure that the

specialized plans are kept confidential for these clients. Also, [Remove comma (unless

introducing a nonrestrictive phrase)] Riordan should consider the possibility of

creating other specialized products as a possibility of advancing its customer base. This

will allow Riordan to keep up with new designs and give them the opportunity to expand

in the industry. Employees of the China entity also need to be signing disclosure

documents ensuring confidentiality with other companies.

Legal Forms of Business

Riordan Manufacturing is a Corporation. Therefore, they are a public company that is


[Wordiness: see if you can remove "that" or "that is"] responsible for complying with

Sarbanes-Oxley regulations. Quarterly financial statements need to be filed [Passive

voice ] on a timely basis. These statements need to be accurate and the officers and

directors of the company need to sign off on the forms verifying that there was no

information omitted and that the information is accurate. The company needs to ensure

that there are no conflicts of interest in any of the departments or concerning any of the

products that are sold. An audit company that is [Wordiness: see if you can remove

"that" or "that is"] responsible for overseeing and paying for external auditors is also a

necessity.

Enterprise Risk Management

Enterprise risk management is an approach to assist management to identify and manage

uncertainties to obtain positive risk objectives. The ERM framework focuses on the

development of a strategy that contains the importance of a risk and internal control

"consciousness" throughout the organization. COSO intended this framework to be an

effective tool for keeping executive officers and directors informed about the

organizational procedures and processes and assist to respond to uncertainties that will

assist management to measure how the organization is managing its own risks.

The COSO enterprise risk management structure recognizes an organization to connect

risk management into strategic objectives and organizational culture. To protect against

the event of a risk situation, all layers of Riordan must determine how its actions will

respond and protect the organization. Organizations that fail to comply with local, state or

federal governmental regulations will exposed [This phrase should end in a verb, not

the participle--will expos (or will expose?)] [Incorrect wording--depending on the


intended meaning, either spell without "ed" or add "be"--will be exposed] the

organization to regulatory risks that will impact [Doctoral rule (although good advice

for any academic writer): "impact" is a noun (a hit). It is informally used as a verb

(impacting the business), but avoid this in academic writing ] the organization

existing assets, earnings, and most often the reputation in the media. Organization

preventive measures provide the internal controls of the day to day [As an adjective, the

previous three words are one hyphenated word] [these three words are spelled as

one hyphenated word] business operations that reduce, limit and [in academic writing,

if this is a series, place a comma before the final conjunction (and)] eliminate the

organizations exposure to tort liability, fines and [in academic writing, if this is a series,

place a comma before the final conjunction (and)] criminal penalties With this in

mind, Riordan Executives [Do not capitalize job names] and [in academic writing, if

this is a series, place a comma before the final conjunction (and)] Directors [Do not

capitalize job names] will take the necessary steps to implement ERM to include:

development of an organization strategy to include risk management; determination of

corporate philosophy and the delegation of risk controls; performance of risk assessments

and determining how much risk Riordan is willing to undertake to generate value;

identifying risk responses, communicating and [in academic writing, if this is a series,

place a comma before the final conjunction (and)] analyzing risk results; and [Unless

the previous phrases contain one or more commas, remove the semicolon(s)--replace

with comma(s)] continued review and oversight to ensure compliance from

management. [Writing suggestion: If this sentence is as long as 50 or more words, it

can be confusing with logic twists, recursions, or long lists. Cut it into shorter


sentences featuring one idea. Shorter sentences are easier to comprehend] What this

means is that Executives [Do not capitalize job names] and Directors of Riordan

Manufacturing must overlap their interests and alig

corporate governance with risk management.

Specific Laws or Aspects of the Law for Riordan Employees

I) Clean Air and Water Act

a. Plastics are so varied [Passive voice ] and are used [Passive voice ] in so many

industries and types of products; they are affected by many regulations across the world

(Murner, 2009). Riordan manufacturing plants located within the United [Redundancy:

remove "located": "Riordan manufacturing plants within the United" means the

same] States and in China is susceptible to review. All inquires must be directed

[Passive voice ] to through the Corporate Compliance Officer to the Chief Legal

Counsel for further guidance.

b. Riordan responsibility is to insure [Use "ensure" unless this refers to an insurance

policy] full compliance of the Clean Air and Water Act by responding immediately to

violation(s) addressed and monitor progress of the violation to insure [Use "ensure"

unless this refers to an insurance policy] no future violations.

c. The responsible Director [Do not capitalize job names] must review, update and [in

academic writing, if this is a series, place a comma before the final conjunction

(and)] follow-up on the issue to insure [Use "ensure" unless this refers to an

insurance policy] full compliance of the law to prevent repeat findings or negative

public media attention that may reflect on the organization.

II). Occupational Safety and Health Administration


a. Compliance of OSHA regulations will reduce work-related injuries, illnesses and [in

academic writing, if this is a series, place a comma before the final conjunction

(and)] death through proper annual workplace safety inspection and review.

b. Reported violations must be addressed immediately by the responsible management

official by taking appropriate action to insure [Use "ensure" unless this refers to an

insurance policy] the safety and health of the employees and insure [Use "ensure"

unless this refers to an insurance policy] the findings are corrected [Passive voice ] .

c. OSHA information is required [Passive voice ] to be posted [Passive voice ] on all

employee bulletin boards to be available for all employees to access and provide

information concerning the workplace and his or her rights under OSHA.

III) Disputes

a. Disputes can arise from employer-employee or the organization and the consumer

concerning his or her differences that cannot be resolved [Passive voice ] .

b. ADR or arbitration dispute resolution provides the parties an opportunity to resolve his

or her issue to minimize the possibility of litigation. Mediation is another option or a

"peer" review, if the dispute is with the employer and employee.

c. Employees can contact the human resource [human resources] manager for further

direction if the dispute cannot be resolved [Passive voice ] within the employee

immediate supervisor or second-line supervisor.

d. Consumer disputes will be resolved [Passive voice ] through the Product Support

Division and elevated through the appropriate chain of command to the Chief Legal

Counsel for final review. The course of action will be to minimize the impact of the

dispute to the lowest level and resolve the consumer dispute with little financial hardship


as necessary.

IV). Federal Trade Commission Act

a. Riordan is committed [Passive voice ] to providing accurate information on all

products sold to a consumer that [Check word usage--If this word refers to a human

being, people are never "that" or "which," they are "who"] meets with state and

federal guidelines.

b. All products carry an express warranty for the quality, abilities, or performance of the

product as provided in the Uniform Commercial Code (Jennings, 2006).

c. Executive management must insure [Use "ensure" unless this refers to an insurance

policy] full compliance of the act to avoid any product liability issues and reduce the

possibility of negligence, intentional tort or [Insert a comma before this word if this is

the last in a list of more than two -- or if it begins a new clause] strict tort liability.

d. Report any legal actions through the Corporate Compliance Officer to the Chief Legal

Counsel who oversees all legal matters for Riordan Manufacturing.

V). Intellectual Property Rights

a. Intellectual property consists of Riordan Manufacturing trademarks, copyrights,

patents, and trade secrets.

b. Trademarks are defined [Passive voice ] under the Lanham Act of 1976 and are

defined [Passive voice ] as a word, name, symbol or other designation that is

[Wordiness: see if you can remove "that" or "that is"] representative of the

organization from others (Jennings, 2006).

c. Trademark or patent infringement is likely to occur abroad, presumably in China where

our [Use "we," "us," or "our" to mean yourself and coauthors, not general


humanity (or yourself and the reader)] 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.

VI). Management and Control

a. Riordan Manufacturing is a profit corporation with unlimited duration, free

transferability of interest, limited liability for shareholders/owners, continuity, and

centralized management (Jennings, 2006).

b. 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 [Passive voice ] .

c. Riordan Manufacturing will comply with the state and federal guidelines as established

for the organization.

VII) Corporate Governance

a. Riordan Executive Managers [Do not capitalize job names] and Directors [Do not

capitalize job names] are involved [Passive voice ] with the responsibility to insure

[Use "ensure" unless this refers to an insurance policy] compliance with the

organization strategy, policies and [in academic writing, if this is a series, place a

comma before the final conjunction (and)] guidelines and accountability to the

stakeholders in the organization.

b. Issues requiring corporate governance principles include: Internal controls, oversight


and [in academic writing, if this is a series, place a comma before the final

conjunction (and)] management of risk, oversight of the entity's financial statements,

and review of the compensation arrangements for the CEO and other executives.

c. 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 [Writing

suggestion: rewrite the sentence to remove "that are"] fair, efficient and [in academic

writing, if this is a series, place a comma before the final conjunction (and)]

transparent.

d. 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.

VIII). 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 [Passive voice ] 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 [Insert a comma before this

word if this is the last in a list of more than two -- or if it begins a new clause]

Corporate Compliance requirements. Notice concerning possible litigation against

Riordan or alleged violations of law by Riordan is required [Passive voice ] to report to

the senior leadership. Riordan encourages employees to share his or her questions,

complaints, suggestions or recommendations to [Possible incorrect preposition--check


appropriateness of "to" (replace with "of")?] the organizational leaders within the

division.

IX). Investigations and Corrective Action

Any and all [Redundancy: "any" includes "all," so leave out "and all"] alleged

violations are to be investigated [Passive voice ] immediately or the Corporate

Compliance Officer will administer the action to be taken [Passive voice ] .

Investigations will be treated [Passive voice ] in confidence to the level that is

[Wordiness: see if you can remove "that" or "that is"] consistent with Riordan

interests and legal requirement Suspected violations will be investigated [Passive voice ]

and documented for submission to the President/CEO and Chief Operating Officer for

review. If the investigation indicates from the results that corrective action is required

[Passive voice ] , Riordan will make a decision on a suitable course of action to acquire,

to include: discipline, dismissal and [Insert a comma before this word if this is the last

in a list of more than two -- or if it begins a new clause] [in academic writing, if this

is a series, place a comma before the final conjunction (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 framework for Riordan to

develop an effective ERM program with strong internal controls to maintain compliance

and establish adequate checks and balances. Riordan Manufacturing will take a proactive

approach in Corporate Compliance by acquiring the enterprise risk management approach

not only to comply with state and federal mandates but [For parallel construction, "not


only" must be followed by "but also" later in the sentence] to insure [Use "ensure"

unless this refers to an insurance policy] Riordan establish measures and internal

controls to prevent, identify, and management risks, exposures and [in academic

writing, if this is a series, place a comma before the final conjunction (and)]

incidents. Being a productive and responsible organization will reflect 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 [This expression is wordy and vague; the sentence means

the same without it] .


References

University of Phoenix. (2013). Riordan Manufacturing Simulation. Retrieved March 10, 2013,

from University of Phoenix

Jennings, M.M., (2006). Business it's legal, ethical, and global environment. Available from the

University of Phoenix eBook Collection database

University of Phoenix (2013) Handouts and Materials from class.

corporate compliance plan bev

Documents