Transcription of Building world-class ethics and compliance programs ...
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Building world-class ethics and compliance programs : Making a good program great Five ingredients for your programIntroduction 1 How did we get here? 2 What are the ingredients? 3 Tone at the top 4 Corporate culture 7 compliance risk assessments 12 The Chief compliance Officer 18 Testing and monitoring 23 Contacts 29 ContentsBuilding world-class ethics and compliance programs : Making a good program great | Five ingredients for your program 1 IntroductionThe expression never a dull moment could have been tailor-made to describe the ethics and compliance function and how it has evolved over the past decade or so. The well-publicized financial scandals that marked the aftermath of the tech bubble in 2002 and the housing bubble in 2008 led the Congress to pass sweeping legislation that called for increased regulation, greater financial transparency, and more rigorous scrutiny of large corporations.
The board and senior management should do more than pay “lip service” to ethics and compliance. They need to empower and properly resource the individuals who have day-to-day responsibilities to mitigate risks and build organizational trust. Corporate culture—A culture of integrity is central to any effective ethics and compliance program.
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