After two stressful months on the job, Ms. Granger has realized that Wiz Corpis "way behind the curve on compliance."While the Compliance Program appears to be sophisticated on the surface, most employees do not seem to know much about it, and thereisn't a Code of Conduct.Even the Wiz Corp's executives seem clueless about the importance of compliance and havejokingly made comments about how best to "get around" compliancepolicies. Ms. Granger further realizes that notwithstanding all the promises she was made when she interviewed for the job, she is not able to access many resources. She is stuck in a basement office in a mostly empty building on the edge of Wiz Corp's campus,and she never interacts with the board of directors.She doesn'thave a sense of how Wiz Corp is doing on compliance since there is no hotline or means for employees to flag compliance concerns. She isso busy "putting out fires" thatshe never has time to make any real progress on any of her compliance program goals, especially since she has not been allowed to hire anyone to assist her.

Answer the following questions, but do not draft a compliance program or any policies.

(a) Do you believe that Wiz Corp must redesign and update its Compliance Program to make it effective? Why or why not? How should Ms. Granger begin?

(b) What guidance should she consult? Would your answer differ if Wiz Corp were a publicly traded corporation?

(c) What actions should she take, and what types of policies should she implement to improve the effectiveness of Wiz Corp'sCompliance Program?