In continuation of the discussion of compliance program “effectiveness” and the challenges of metrics and measurement, is the concept of benchmarking—an oft misunderstood term. Simply put, it is the process of comparing one’s own business processes and performance to industry standards and peers to determine a relative degree of success.
Occasionally one can still find reference to a board director or company executive stating, “We decided to “benchmark” our compliance program, but actually meaning “We brought in a consultant who linked the elements of the Federal Sentencing Guidelines to our program, gave us a grade, and then talked to us about what’s going well and what could be improved.”
