High-Quality Program (HQP) Framework
A path to ethics and compliance success for programs that promote integrity and mitigate risk
Today’s ethics & compliance landscape is more complex than ever before.
With expanding operating geographies, consumer protections like GDPR and ongoing reputational risk, today’s companies need a robust ethics & compliance solution that ensures integrity. The High-Quality Program (HQP) Framework provides a structure for success and positive ethical and financial outcomes across all levels of an organization.
The HQP Framework serves as a guide for organizations to create new, effective E&C programs or to evaluate existing programs and determine areas that need improvement.
Organizations deserves an ethics & compliance program that’s as agile and dynamic as today’s marketplace. The HQP Framework provides an end-to-end solution for building and sustaining ethics & compliance programs that are proven to:
- Increase return-on-investment for your E&C efforts;
- Ensure positive ethics outcomes organization-wide;
- Promote C-suite buy-in with easy-to-read progress reports and data.
What are High-Quality Programs (HQPs)?
HQPs are ethics & compliance programs that operate at the highest-performing standard determined by ECI researchers and practicing ethics leaders. At its core, HQP is based on five guiding principles first researched, developed and published by academics, E&C leaders and former Deputy Attorneys General (DAGs) in the Principles & Practices of High-Quality Ethics & Compliance Programs Blue Ribbon Panel Report.
- E&C is central to business strategy.
- The organization encourages, protects and values the reporting of concerns and suspected wrongdoing.
- E&C risks are identified, owned, managed and mitigated.
- Leaders at all levels across the organization build and sustain a culture of integrity.
- The organization takes action and holds itself accountable when wrongdoing occurs.
When organizations have E&C programs that align with these principles, they are 76% less likely to observe False Claims Act (FCA) violations, 38% less likely to observe Foreign Corrupt Practices Act (FCPA) violations and 65% less likely to observe other white-collar crimes.
A new, proven standard of determining program success.
Organizations and ethics and compliance programs are increasingly complex and take into account a multitude of factors, and the need for an objective measure of efficacy is important.
The HQP Framework operationalizes the five guiding principles of HQP with 27 supporting objectives and over 100 leading E&C practices. We then apply a 100 point maturity curve scale to each principle and supporting objective, giving specific insights on how organizations programs are assessed.
It is important to note that HQP is not a score, and the goal is not to achieve 100 in each area. Every ethics and compliance program is unique and the HQP Framework is designed to be an instructional and insightful guide for program development and continuous improvement.
Applying the Framework is easy for all sizes of organizations.
With those metrics in mind, how organizations can apply the framework to their E&C program is determined by a combination of the following interlocking factors:
- Framework – principles, supporting objectives and leading practices;
- Risk Factors – taking into account risk from all areas of the organization, following the structure of Enterprise GRC
- Program Implementation – based on leading practices and areas of needed support.
The top portion of the cube matrix represents the 5 principle of the framework, which are supported by 27 Strategic Objectives and reinforced by over 100 Leading Practices.
The left side of the cube matrix defines how HQP deploys an expanded view of risks that follows the structure Gartner introduced in 2014 known as Enterprise GRC (E-GRC) or Integrated Risk Management (IRM).
The HQP Framework calls for more cooperation with other areas of the organization and a holistic approach to embedding E-GRC into the organizational structure and strategy.
The right side of the cube matrix lists methods of implementation, based on the leading practices that are a factor in the HQP Framework.
Based on the risk and the desired execution element, the HQP principle and its Supporting Objectives and Leading Practices will define the needed process, identify execution improvement or validate an existing process.
All 3 factors intersect to present an HQP dimension for connection, analysis and review.
This granularity is important in helping you make the right improvements at the right time. Each intersection creates a building block for a culture of integrity in organizations and High-Quality E&C Programs where every element is cared for.
Why is a culture of integrity important?
Organizations with strong cultures benefit from numerous positive ethical outcomes including:
- Employees that feel they can raise concerns with their supervisor;
- Employees that are satisfied with the organization’s response when they report;
- Higher rates of reporting observed misconduct; and many more.
The HQP Framework sufficiently satisfies the latest Department of Justice Guidance on program effectiveness.
Earlier this year, the Department of Justice Criminal Division unveiled their latest guidance, Evaluation of Corporate Compliance Programs, at ECI’s IMPACT2019 conference. The guidance outlines the criteria by which the DoJ determines the effectiveness of compliance programs by asking three simple questions:
- Is the corporation’s compliance program well designed?
- Is the program being applied earnestly and in good faith? In other words, is the program being implemented effectively?
- Does the corporation’s compliance program work in practice?
The design and implementation of the HQP Framework ensures that each and every criteria of the DoJ’s guidance is cared for and satisfied. The Framework is also subject to continuous re-evaluation and updating to stay current with future impending changes to the guidance.
This means that by implementing the HQP Framework in your organization, you are sure to stay ahead and on top of regulatory shifts now and in the future.
Get started on your path to success with the HQP Assessment.
The HQP Assessment takes all the elements of the Framework and evaluates your ethics and compliance program based on each operating principle. Using your Assessment, you can determine your areas of success and areas of most needed improvement.
Benchmarking data is also available for comparison of E&C programs in specific industries, allowing you to compare your assessment results.