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Moving Beyond Compliance

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IF YOUR COMPANY HAS ALREADY SET UP an Ethics and Compliance (E&C) system, you’ve taken the first important step towards embedding ethics.

Basic E&C checklist

Although the E&C function is relatively new, there is broad consensus on the elements of an effective programme (see Box 1). Front and centre are risk assessment, clear codes and policies, and putting in place the right organisational roles, structures and resources. Next, come training and communication ’ vital for on-boarding employees ’ proper internal controls and a safe, anonymous, third-party hotline for reporting violations. Finally, penalties and regular audit and reporting cycles help to ensure that standards are upheld.

In addition, the US Department of Justice and US Securities and Exchange Commission list four key things they see as hallmarks of an effective E&C programme:

Commitment from senior management.

Incentives (i.e. personal evaluations and promotions, rewards for ethics and compliance leadership) and disciplinary measures.

Due diligence around payments to third parties, such as agents, consultants and distributors.

Merger and acquisition (M&A) due diligence and integration.
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Keywords: compliance; corporate responsibility; corruption; reputational risk; sustainability; values

Document Type: Research Article

Publication date: January 1, 2015

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