In this posting, we will discuss the leader of the organization and his or her responsibility and requirement to drive the ethics and compliance program.
Why do organizations start ethics programs? Although there are myriad of reasons for ethics and compliance programs, most often they are the result of external circumstances rather than a moment of inspiration by the President/CEO.
Sometimes, it is an external event that caused the organization great pain, either in dollars, reputation or other major issue. Perhaps the CEO or the organization’s general counsel attended a seminar where the need and benefits of an ethics and compliance program was a topic. Often, the genesis of an E&C program is an industry standard that is introduced through an industry oversight group.
As with any new metric, the ethics and compliance roll out is completed with fanfare, enthusiasm and resources. Everything rolls along with speed, alacrity and clear vision. After a period of time, the novelty wears off, the originating impetus us resolved and the management team starts attacking other more “critical” alligators in the swamp.
This is where the “tone from the top” must reenergize the E&C program. This can be done in a wide variety of ways with the most effective ones being those consistent with the organizations vision and the CEOs management style. Effective techniques include CEO headlining a short Ethics training event or adding an ethics update as part of an operational or financial update to the employees. Providing employees with the latest developments in the organizational climate reviews and surveys are also excellent methods to energize the Ethics and Compliance Program.