
A journey of a thousand miles begins with one step.
Lao-tzu (604 BC – 531 BC)
Good compliance management is the foundation of an organization’s
commitment to business ethics. Understanding these core principles and
applying them effectively is the first step in creating the type of enterprise
that will thrive in today’s business environment. ethicsLINC can provide
the expertise you need to make these programs successful.
Companies began to look seriously at what constitutes “an effective
compliance program” after the issuance of the Federal Sentencing
Guidelines for Organizations by the U.S. Sentencing Commission in 1991.
The Guidelines defined an effective compliance program as one that was “reasonably designed, implemented and enforced so that it generally will
be effective in preventing and detecting criminal conduct,” and created
the steps that would be viewed as essential if an organization’s
compliance program was to be deemed effective.
An effective compliance program must, at its core, focus on managing
processes. However, it became clear to those companies determined to
have effective compliance programs that processes alone were not
enough. They recognized the need for strong ethical leadership based on
core values of integrity and honesty. It also became clear that this tone
needed to be set at the top of the organization and communicated
consistently by management at all levels.
The companies recognized as compliance leaders understood (or quickly
learned) that even a well-crafted code of conduct would not address every
situation that an employee will likely face. They understand that employee
decision making has to be supported by senior management in a way that
emphasizes choices designed to ensure the long term health of the
organization, takes the concerns of stakeholders into consideration, and
consistently demonstrates that leaders make choices based on performing
ethically, even if another choice might be more expedient at the moment.
The discipline of compliance management in the best companies evolved
to include a focus on ethical values as part of effective programs.
In November of 2004, the Guidelines were revised, in part as a response
to the scandals surrounding Enron and other corporations. Organizations
were required to create a “culture of ethics” that will encourage lawful
behavior by its employees. “Incenting” ethical behavior was added to the
task of “preventing and detecting” illegal or unlawful behavior. At ethicsLINC, we understand that link between good, effective compliance
management and the ethical choices made by everyone in your
organization. We can help you implement compliance and ethics
programs in a cost-effective, timely manner.







