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Power Plant Program Manager Sings Praises for the Mock Audit


Last week I attended the Society for Corporate Compliance and Ethics (SCCE) Energy and Utilities Conference here in Houston. As usual, SCCE put on a great event, the speakers and topics were all first-rate. As you might expect at such an event, the informal conversations with other compliance practitioners gave an opportunity to learn about new and different approaches to compliance. At lunch on the second day, I had such a conversation, which to my surprise, was not with a Chief Compliance Officer (CCO) or even compliance practitioner of an energy company but with a Program Manager for a utility concern.

I admit that I normally do not attend any of the breakout sessions for the utilities at the conference and generally when forced to sit through a session focused on the utility industry, it does not take too long for my eyes to roll up inside my head. However after this lunch conversation, I will certainly have to revise my disdain for listening to the utility presentations. The person is a Program Manager in his company's Power Plant Process group and he told me about the 'Mock Audit' that his company performs in its power plants across the country.

He explained that his industry is heavily regulated at both the state and federal level. Power plants are subject to numerous levels of oversight including various ISO standards to which they must comply. ISO is the International Organization for Standardization and it develops and publishes International Standards for various industries and organization. The ISO 9000 standards provide guidance and tools for companies and organizations who want to ensure that their products and services consistently meet customer's requirements, and that quality is consistently improved. One of the components of ISO 9000 compliance is an internal audit to check how a quality management system is working. But, for the utility industry, there are additional, more formal audits by various state and federal regulatory bodies, including both North American Electric Reliability Corporation (NERC) and the Federal Energy Regulatory Commission (FERC). In other words, the utility industry is subject to numerous rules and regulations which require compliance audits.

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Visit the FCPA Compliance and Ethics Blog, hosted by Thomas Fox, for more commentary on FCPA compliance, indemnities and other forms of risk management for a worldwide energy practice, tax issues faced by multi-national US companies, insurance coverage issues and protection of trade secrets.

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© Thomas R. Fox, 2013

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