|What is an Internal Compliance Program (ICP)?|
|Written by Crystal|
|Friday, 07 January 2011 11:18|
Compliance is an integral part of everyone’s day-to-day activities. Whether it be Operations personnel or those in Management, each is responsible for incorporating all aspects of compliance activities, documentation, training, and reporting into their daily operations. That’s where an Internal Compliance Program comes into play…
An ICP is, in essence, another Procedure developed to detect and prevent company violations of NERC Electric Reliability Standards. The Federal Energy Regulatory Commission (FERC) has stated on numerous occasions that it expects to see a "culture of compliance" in place and in force for each registered entity.
Although Internal Compliance Programs are not mandatory, FERC has been consistent in their message that if a company acts aggressively to adopt, foster, and maintain an effective corporate culture of compliance, and has in place rigorous procedures and processes that provide effective accountability for compliance, but a violation nonetheless occurs, the Commission may provide a significant reduction in, or even in some cases the elimination of, the civil penalty that otherwise would be imposed. This has been noted in several FERC policy statements that I’ve referenced and linked for you at the end of this article.
Factors that FERC is looking for in an ICP are specified in their Revised Policy Statement on Enforcement. Along with this, the Regional Compliance Implementation Group (a working group overseen by NERC’s Regional Entity Management Group) developed a Policy Statement to create a Compliance Guidance Document that outlines attributes of a good compliance program.
Some finer points from both of these sources include the following:
It may seem like a huge undertaking, but can be well worth the effort. Take some time and develop a comprehensive Internal Compliance Program (ICP), it’s good business practice and can help mitigate a penalty. If you need help, let me know, it’s one of the great services my team provides!
For additional reading regarding the benefits of an ICP, go to:FERC Revised Policy Statement on Enforcement – Docket No. PL08-3-000 (May 15, 2008) FERC Policy Statement on Compliance – Docket No. PL-09-1-000 (Oct 16, 2008) FERC Revised Policy Statement on Penalty Guidelines – Docket No. PL10-4-000 (Sep 17, 2010)