Three Steps to a More Effective Ethics & Compliance Program



Despite an increasingly clear understanding among regulators and practitioners of what makes an ethics & compliance (E&C) program effective, corporate slipups and scandals continue to occur. As LRN’s Susan Divers and Mike Eichenwald explain in this Inside Counsel article, that may be because “many programs focus too much on layering on rules and regulations – and not on defining corporate values and the specific behaviors they want to see from managers and employees, and holding them accountable when they fall short.”

The article outlines three clear steps Generals Counsels, Chief Ethics Officers and their teams can follow for more effective E&C programs based on values and behavior, instead of relying on checklists and layers of rules:

  1. Articulate a set of shared and sustainable values that truly reflect the best of what the company stands for and believes in.
  2. Define a set of behaviors that reflect those values that people at all levels of the organization should espouse.
  3. Cut unnecessary rules altogether.

As the story concludes, “a strong corporate culture, based in values, can lead to a simpler, clearer and more effective compliance program than an arbitrary checklist of rules and multiple layers of policy.”