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.
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.
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