Communication is an essential ingredient in the program, and will be a hallmark of success for the program.  Not only does the successful program include multiple vehicles of administering critical organizational information, but repetition of this consistent message must be completed.  More importantly, the management—from the board of directors, senior management, and the operational day-to-day supervisors is necessary for comprehensive ethics and compliance performance.  The message is not only repeated and consistent, but is simple and is reinforced with a disciplinary action process that holds each level of the organization accountable.  Senior managers are held to an even higher standard, not only due to their positions, but also due to the more extensive training requirement within the ethics program.

The Corporate Ethics and Compliance Officer (CECO) reports formally to the President and CEO (the boss), has direct access to them and provides a written and briefed reports on a quarterly basis.  The program must also, at minimum, an annual internal audit by the corporate quality function, and ideally an external audit on a recurrent basis. 

The Code of Conduct should contain two major components: ethics rules and code compliance procedures.

The complete administrative process for the company is detailed in a series of ethics and compliance procedures or work instructions that provide the user a step-by-step walk through of any aspect of the program.  The process covers everything from initiating a report and report resolution to training, awards, and audit of the overall program.

What are the characteristics of a functional and useful Ethics and Compliance Program? 

Typical ethics and compliance programs are created a response to a serious event or the anticipation of a future legal or other business requirement. 

The Ethics program must have wide stakeholder acceptance and must be designed with the end users in mind.  The Chairman and the CEO (the boss) must take ownership and set the tone for a strong and driven plan for program implementation.  The Code of Business Ethics and Conduct must be a senior company document and augment corporate vision and mission and core values statements and become the focal point of company operations.  Additionally, the policies, procedures, tools, and work instructions were revamped to reflect ethics and compliance as a key aspect of the company culture.

The ethics program roll-out must be comprehensive and permeate every level of the organization. It originated from a committed senior management team (the boss), and the existence and applicability of the program was repeatedly communicated to ensure wide dissemination and acceptance.  The training on the base ethics program components must be administered to all employees upon hire and be reinforced on a recurrent basis with multiple follow-on and more detailed training modules.  These modules are both delivered in person and are also available in electronic distance learning formats.  These training modules benefit from a continuous process which includes testing, surveys, and focus groups addressing topical issues from the field and through the anonymous independent ethics violation reporting service.

Training has been administered in a wide array of media, programs, and includes both outside experts in addition to formally trained internal compliance and ethics professionals.  Formal training modules must be constructed and administered for all hands, for supervisors, weapons carrying employee/contractors, purchasing agents, senior management team members, the board of directors, and for other specific audiences.   Training modules should have standardized exams to confirm successful completion of the training.  Initial training should also augmented by annual maintenance   syllabi with test requirements for all hands.  There should also a special annual refresher training module for those who have duties that require FCPA or other specific requirements.