Corporate ethics and compliance (E&C) programs are playing an increasingly important role in the US Department of Justice’s (DOJ’s) civil and criminal enforcement policies. This role reflects DOJ’s growing recognition that effective E&C programs can benefit companies, their stakeholders, and the public through the prevention, early detection, and resolution of misconduct. DOJ has publicly stated that it is, therefore, actively considering (1) the critical qualities that define an effective E&C program, and (2) available metrics for measuring and assessing those qualities. This white paper provides a summary of the Ethics & Compliance Initiative’s (ECI’s) research to date and the input of our membership community regarding the critical elements of an effective E&C program. It further addresses the metrics that DOJ can use to assess a company’s progress in implementing those elements.
Critical Elements Of
An Effective Ethics &
ECI shared a copy of the Measurement Framework with officials at the Department of Justice, along with a companion report that summarized the work of the organization to define and measure an HQP.