Just what is a “compliance-first” company?

How does a company describe and demonstrate its commitment to compliance? And how does it prove to regulators and law enforcement it cultivates, monitors, and encourages a proactive, compliance-first company culture? If, heaven forbid, the Department of Justice (DOJ) came calling with questions about a particular legal issue, how would the company describe its efforts to comply with the relevant law or regulation?

Mia Reini, senior manager, corporate compliance and enterprise risk management at The Home Depot, wanted to be proactive. The Home Depot, headquartered in Atlanta, is the world’s largest home improvement retailer. With approximately 500,000 employees in more than 2,300 stores across North America, the company is supported by a robust compliance program.

But how could the company prove its compliance bona fides to a regulator, should one ever come knocking on its door? Reini said The Home Depot decided to create a document that would answer questions the DOJ or another agency might someday have about the company’s compliance program. After reading the DOJ’s “Evaluation of Corporate Compliance Programs” last updated in June 2020, she said she thought, “We should really write out our answers to these questions.”