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.