For the past seven years, LRN has conducted its annual survey of Ethics and Compliance programs in search of benchmarking data, suggestions of leading practices, and trends. In 2012 LRN adopted the Program Effectiveness Index as a tool to determine the impact of compliance programs.
The challenge with index is figuring out the difference between correlation and causation. The report is quick to point out the difference. For example, the public celebration of ethical leadership is a characteristic of programs with extremely high Program Effectiveness Indexes. But having a public celebration will not necessarily make your compliance program more effective.
I found the spending and staffing section useful. The average spend on compliance was $100 per employee, with highly regulated industries such as financial services averaging $130 per employee. As for headcount the average was 2.3 FTE per one thousand in highly regulated industries, above the 1.4 FTE overall average. You should note that the survey did not find a correlation between spending/staffing and effectiveness.
Annual assessments were highly correlated with effective programs. Of course if you are registered as an investment adviser, you are compelled conduct an annual assessment under the Compliance Rule 206(4)-7.
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