Tone from the top is not the first critical measure of an effective ethics program but is typically the most important aspect of an ethically excellent enterprise.   An ounce of prevention is worth a pound of cure is more than a saying.  The best time to identify a world class employer with leadership committed to ethical conduct is prior to employment. 

Allen Wass, CPC of Sanford Rose Associates recently posted a commentary discussing the importance of organizations and their sets of values which determine their perspectives and actions.  A company forms an ethical foundation by creating and openly listing the principles it follows, and these standards guide its employees.  He provides two examples:

Company #1

-Integrity

-Safety, safety, safety

-Respect

-Competitiveness

-Teamwork

-Results, not reasons-make it happen

 Company #2

-Nothing is more important than the safety of our people

-Dedication to the customer

-Respect for the dignity, rights, and contributions of each associate

-Mutually beneficial supplier relationships

-Active participation in and communication with the community

-Commitment to integrity and high ethical standards.

Company stating their values are more likely to be operationally excellent with respect to ethical behavior.  Other techniques available to the applicant are interviews with former and current employees and research to include recognition of the organization by industry associations or ethics and compliance oversight groups.

Being able to identify these enterprise values before you sign on to the team is a “freebie” and when available should always be checked out.

Next time, we will discuss the leader of the organization and his or her responsibility and requirement to drive the ethics and compliance program.

Does the program have appropriate responses in place to respond and prevent future occurrences and modifies existing standards and procedures accordingly?

There are many components common to all seven of the guidelines for a quality ethics and compliance program.  

 
Ways to reasonably reduce the prospect of future occurrences of non compliant behavior:

A Code of Conduct

Corporate policies and procedures

Assignment of a competent and respected ethics and compliance officer

Company hotline

Audits

Investigations

Education and training.

Specific tools and processes to assist in the basics include:

Ethics Training, Targeted Compliance training

Newsletters and other communications tools

Ethics and Compliance Website

Screening procedures prior to and during employment

Misconduct database management

Do these look familiar?  They should as they permeate all of other six guidelines for an effective ethics and compliance program.  Additionally as in any other enterprise activity, continuous improvement through proactive preventative and corrective action processes are essential in each of the areas noted above.

Now that we have worked our way through the basics, future postings will focus on specifics and examples to assist and illustrate how to use these programmatic to improve your organization’s ethics and compliance performance.  More importantly, we will do this to make these processes assist your business to not only run more efficiently but more profitably, short and long term and increase enterprise value.