Your program has excellent standards in place; Code, policies and procedures and buy-in and acceptance by the management and employee team. The training program is comprehensive, the audits and surveys confirm the program effectiveness. Despite these strengths, reports into the program identify non compliant and unethical behavior. The screening process has not been effective but the internal system works. When the facts and performance indicate an employee or contractor does meet the standards and the expectations of the enterprise, swift action is necessary following established processes and procedures.
First step is to follow established processes and administrative procedures to ensure appropriate corrective actions are employed. Second step, review processes to confirm that reports when detected were reported. If this is not the case, preventative actions must be incorporated including review of existing processes to continuously improve the overall company standards, including Code and policies and procedures. This is important, especially when supervisors, managers and senior management team members are involved. All employees are held to the standard; the leadership must be viewed organizationally as always meeting the standard.
No compromise for profit, past performance, service time or organization position can be allowed. Measure the performance or the lack thereof and take the appropriate disciplinary action.