1. Does the program have compliance standards and procedures in place that can reasonably reduce the prospect of criminal conduct?
2. Does the program assign high level personnel to oversee compliance?
3. Does the program avoid placing people in responsible positions that they know or should have known have a propensity to engage in illegal activities?
4. Does the program communicate the standards and procedures through training and other mechanisms?
5. Has the program established monitoring, auditing, and reporting systems where employees can report criminal conduct without fear of retribution?
6. Does the program enforce the standards including discipline of individuals for failure to detect and report offenses?
7. Does the program have appropriate responses in place to respond and prevent future occurrences and modifies existing standards and procedures accordingly?
Check in with the ethicsgeneral.com website for some discussion of these characteristics over the next couple of months.
We will be looking forward to your comments, questions and suggestions.