Developing an Adequate Internal Compliance Program for the Royal Netherlands Air Force Command

This chapter examines how an adequate Internal Compliance Program (ICP) for the Royal Netherlands Airforce (RNLAF) was developed. In order to create an adequate ICP, it is essential to determine which legal and other aspects should be incorporated in the ICP framework. To deduct these relevant aspects of the environment the RNLAF operates in, a Political, Economic, Social, Technological and Legal (PESTL) analysis is used. Furthermore, the different ICP frameworks are compared in order to make a combination of them to create the most adequate ICP for the RNLAF. We conclude that this should be a combination of mainly US ICP Frameworks as of the fact that the RNLAF is mostly US orientated. The COSO model as an internationally widely used best practice framework is the core. The combination of the PESTL analysis, the legal framework and the chosen ICP frameworks together result in an 11 pillars ICP, which we consider is the most adequate ICP for the RNLAF. Leading principle in combining all the aforementioned elements, is that the ICP has to be tailored to its organizations’ characteristics (e.g. nature of items, size of the organization, national, regional and global footprint). We understand that there is no one-size-fits-all approach, but one needs to design an ICP that specifically fits the given organizational structure, its size and daily operations.