Compliance

Compliance Overview

From the outset, we have taken compliance very seriously at The Expert Institute. Whilst many of our competitors’ names have been “dragged through the mud” as part of larger expert network investigations in the past, we have managed to maintain a clean slate. We have had a chance to learn from others’ mistakes, and improved upon our compliance framework over time. More importantly, however, we took a rigorous approach to compliance from the outset.

We see compliance as a three-way responsibility between The Expert Institute, the experts that we refer, and our clients. Each stakeholder holds responsibilities on which the others depend – and therefore a strict enforcement of the rules is vital to ensuring compliance across the board. This is why we require experts to agree to a clear set of rules at the outset, which are detailed in our terms and conditions.

Further, we interview, vet, and check the background of each expert that we recommend for a client engagement. We then offer compliance training through our online tutorial, which is customized to satisfy each client’s unique needs. Each new engagement opportunity is reviewed in detail before it is introduced to any experts. This ensures that confidentiality is maintained and reveals any potential conflicts of interest, before any sensitive information is disclosed. In addition, our backend technology support systems are designed to quickly integrate custom compliance requests from our clients because we understand that, beyond industry standards, each client has different needs and requirements. In the following section, we provide an overview of our compliance framework and some of the practices and policies that we have implemented to date.

Expert Compliance

CLEAR ENGAGEMENT RULES

Before any expert is recommended to a client, the expert must agree to our terms and conditions, which clearly define the rules of engagement an expert must adhere to when considering and accepting a consulting opportunity. These rules are intended to ensure that the expert maintains confidentiality regarding the client and the consulting opportunity, does not have a conflict of interest, does not breach any existing agreements or duties, and does not violate any laws, among others.

EXPERT SCREENING

In order to become eligible as an expert with The Expert Institute, experts must undergo a rigorous vetting process. We start by collecting a vast amount of relevant information from applicants, including academic attendances and degrees, awards and certificates, association and network memberships, as well as detailed employment history information. Our in-house expert recruitment specialists individually interview each applicant and verify select application information with third party sources.

COMPLIANCE EDUCATION

Once an applicant has made it through our screening process, we are here to help explain and continue to build awareness of expert compliance requirements. The online compliance tutorial helps explain the cornerstones of our compliance framework and can be customized by clients for each engagement. In addition, every expert has an individual contact at The Expert Institute who they can direct specific compliance related questions to.

LIVE EXPERT INFORMATION

Once an applicant has been admitted to participate in consulting opportunities through The Expert Institute, the expert has the ability to update their information stored with The Expert Institute at any time. Again, a review by one of our in-house expert recruitment specialists takes place to ensure the accuracy of all new information submitted.

Client Compliance

Each of our clients has a different internal compliance policy. At The Expert Institute, we take a conservative approach to compliance. This creates a solid foundation for a compliance framework that our clients feel comfortable with. It is our clients responsibility, however, to ensure that their internal policies match what we are doing at The expert Institute, and to inform us if they require a more stringent approach.

The Expert Institute further enables clients to work with experts in a compliant manner. As client compliance requirements might be general in nature (apply to all expert engagements) or project specific in nature (apply only to a specific project), we provide the opportunity to customize compliance requirements for both instances

GENERAL COMPLIANCE REQUIREMENTS

The first time a client engages our services, one of the main points we discuss is compliance. We will ensure that the individual compliance requirements of each of our clients are fully integrated into our internal processes. Clients are required to submit any expert compliance specifications beyond what The Expert Institute outlines in its terms and conditions. This way, we can integrate all of these individual requirements into our backend technology support systems, ensuring that they are adhered to every time we work on an expert referral request for that client. Examples of past general compliance requirements include:

  • "DO NOT CONTACT ANYONE FROM A SPECIFIC INDUSTRY OR CATEGORY."
  • "DO NOT CONTACT ANYONE ABOUT THIS OPPORTUNITY UNTIL WE HAVE APPROVED THE INDIVIDUAL BASED ON THEIR IDENTITY AND BACKGROUND."
  • "DO NOT INTRODUCE EXPERTS TO US THAT ARE CURRENTLY EMPLOYED BY A SPECIFIC COMPANY / ORGANIZATION"
  • "DO NOT INTRODUCE EXPERTS TO US THAT WERE EMPLOYED BY A SPECIFIC COMPANY / ORGANIZATION WITHIN A CERTAIN TIME FRAME IN THE PAST."
  • "DO NOT INTRODUCE EXPERTS TO US UNLESS OUR CHIEF COMPLIANCE OFFICER HAS PRE APPROVED THEM."

GENERAL COMPLIANCE REQUIREMENTS

As part of a specific expert referral request, clients are required to submit any expert compliance specifications beyond what The Expert Institute outlines in its terms and conditions. This way, we can incorporate any compliance requirement into the expert selection process before contacting relevant experts. Examples of past project compliance requirements include:

  • "DO NOT INTRODUCE EXPERTS TO US THAT ARE CURRENTLY EMPLOYED BY A SPECIFIC COMPANY / ORGANIZATION"
  • "DO NOT INTRODUCE EXPERTS TO US THAT WERE EMPLOYED BY A SPECIFIC COMPANY / ORGANIZATION WITHIN A CERTAIN TIME FRAME IN THE PAST."
  • "DO NOT CONTACT ANYONE ABOUT THIS OPPORTUNITY UNTIL WE HAVE APPROVED THE INDIVIDUAL BASED ON THEIR IDENTITY AND BACKGROUND."
  • "DO NOT INTRODUCE EXPERTS TO US UNLESS THEY HAVE MADE CERTAIN AFFIRMATIONS OR ANSWERED SPECIFIC SCREENING QUSTIONS"
  • "DO NOT INTRODUCE EXPERTS TO US UNLESS OUR CHIEF COMPLIANCE OFFICER HAS PRE APPROVED THEM."

COMPLIANCE TRACKING

At The Expert Institute, we have a highly customizable backend technology support system at our disposal. Not only are we able to accommodate nearly all of our clients’ custom compliance requirements, but we can also track them in a reliable and secure manner. These tracking protocols can be shared with our clients on an individually agreed upon frequency to ensure maximum transparency and accountability.

ADDITIONAL RESOURCES

Carlo V. di Florio, director of the SEC Office of Compliance Inspections and Examinations, recently voiced his opinion on the use of “expert networks” and recommended a compliance approach very much in line with what we have developed at The Expert Institute. He indicated that investment firms “should address any increase to their compliance risks that expert networks may pose, and build appropriate controls around information obtained from expert networks, at both the front end and the back end.” Schulte, Roth, & Zabel LLP did a great job summarizing Carlo V. di Florio’s recommendations, which can be reviewed here. A complete copy of the remarks made by Mr. di Florio can be found here.