What makes a high-quality ethics & compliance program?
In April of 2016, the Ethics and Compliance Initiative (ECI) released the final version of its report, Principles & Practices of High-Quality Ethics & Compliance Programs. The report was prepared by a Blue Ribbon Panel of prominent ethics and compliance practitioners, academics, white collar and whistleblower attorneys, as well as former enforcement officials. Ethics and compliance practitioners and other members of the public were invited to offer comments on a draft of the report and their feedback was included in the final report.
The final report provides detail about organizations with ethics and compliance programs that go beyond the minimum standard. The report discusses five core principles that are shared by these organizations:
- Principle 1: Ethics and compliance is central to business strategy.
- Principle 2: Ethics and compliance risks are identified, owned, managed and mitigated.
- Principle 3: Leaders at all levels across the organization build and sustain a culture of integrity.
- Principle 4: The organization encourages, protects, and values the reporting of concerns and suspected wrongdoing.
- Principle 5: The organization takes action and holds itself accountable when wrongdoing occurs
The report also identified specific objectives, practices and pitfalls to avoid that have enabled organizations to raise the bar on ethics & compliance and set themselves apart from their peers.