Assignment of a competent and respected ethics and compliance officer is not only a critical requirement for a quality program but is also a mandate for those companies doing business with the Federal government.  Additionally, the ethics and compliance officer must have direct access to the senior company leadership, either the CEO or to the board of directors. 

However, most importantly, the ethics and compliance officer must have the trust and confidence of all the stakeholders in the organization to include but not be limited to employees, managers, customers, vendors, and industry partners.

 
“In looking for people to hire, you look for three qualities: integrity, intelligence, and energy. And if they don't have the first, the other two will kill you.” -Warren Buffett

Does the program have compliance standards and procedures in place that can reasonably reduce the prospect of criminal conduct?

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 criminal conduct include the basics:

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