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.