Bulletin on Corporate Compliance Programs

Competition Bureau

April 9, 2008

Table of Contents

• Preface



• Part I - Introduction



• Part II - Importance of Compliance
  1. Why Is Compliance Important
  2. The Benefits of a Credible and Effective Corporate Compliance Program


• Part III - Fostering a Culture of Compliance



• Part VI - Basic Requirements for a Credible and Effective Corporate Compliance Program
  1. Senior Management Involvement and Support
  2. Corporate Compliance Policies and Procedures
  3. Training and Education
  4. Monitoring, Auditing and Reporting Mechanism
  5. Consistent Disciplinary Procedures



• Part V - Consideration Given to a Corporate Compliance Program
  1. Generally
  2. Specifically
     1. Where Senior Management Is Involved in the Breach
     2. Corporate Compliance Program Implemented as a Sham
     3. Impact on the Bureau's Decision to Pursue Competition Act Matters Under the Civil or the Criminal Regime
     4. Due Diligence Defense
     5. Alternative Case Resolution (ACR)
     6. Immunity from Prosecution and Leniency
     7. Sentencing and Civil Remedies



• Part VI - Conclusion



• APPENDIX A - Corporate Compliance Program Framework



• APPENDIX B - Certification Letter



• APPENDIX C - DOs and DON'Ts



• APPENDIX D - Selected Bureau Publications and Multimedia Tools