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BOILER PLATE FOR AN ETHICS PROGRAM; third of three postings

3/4/2014

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As previously noted, an open line service, an independently-operated-one, provides access to all employees to make reports in multiple languages, anonymously, ensuring no retaliation to the reporting employee.   This service should be augmented by a companywide poster program that highlights contact points for the service.

In addition to internal and external audit assessments, ethics and compliance should be integral parts of the overall business risk assessments provided by insurance providers on a regular basis.  Additionally, internal assessments maybe conducted in focus groups where small groups of employees are convened in a facilitator format to discuss current and potential ethics and compliance issues.  Comprehensive surveys should be developed and analyzed by professionals to determine the effectiveness of the program.

Ethics teams must have a broad base with the direct supervisor identified as the key member for all employees.  Additionally, key personnel should be identified as ethics technical experts to assist in administration of the program.  Basically, the ethics experts provide technical information to those who are not comfortable discussing potential and actual issues with their supervisor.  The Human Resources office is also in the process of incorporating Ethics metrics into the annual performance review procedure.  

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    MGen. Kevin Kuklok (USMCR, Ret.) knows that compliance is an investment that can pay dividends  for your organization and your bottom line, and he can help you efficiently manage this growing issue area.

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