Company Values
Company values are the standards and principles that describe your organization’s culture and guide its operations. Company values are typically sets of single words or short phrases, not full sentences.
Communications
Communications on ethics and compliance topics can take an unlimited number of forms. The messages can be ‘evergreen’ or time-sensitive, and they can be transmitted electronically, verbally, or on paper.
Risk assessment is a continuous process by which risks (potential occurrences that could negatively impact an organization’s key goals) are identified, prioritized and addressed. There is no one-size-fits-all or widely adopted standard for risk assessment.
Risk Assessment
Inquiry and reporting mechanisms are channels, like a dedicated phone line or online form, by which employees can ask a question or report potential misconduct.
Inquiry & Reporting
Mechanisms
A code of conduct is the foundation of an effective ethics program. A code summarizes a company’s expectations for employees and others who act on its behalf. It should be simple and concise.
Code of Conduct
Once it is determined whether an allegation occurred, the company can can take the necessary corrective actions. To reinforce ethical behavior, the company may also choose to reward in some way an employee who came forward or for doing the right thing.
Discipline
An Ethics & Business Conduct Policy documents the company’s ethics program, outlining key program elements like the code of conduct and training, and describing the roles and responsibilities of leadership. It should also explain how employees can report misconduct.
Program Structure
Leaders demonstrate their commitment to ethics every day through their words (when communicating with employees or other business partners) and their actions (by following the rules, respecting others, and responding appropriately to employees’ concerns).
Leadership Commitment
Company policies, which are generally based on laws, regulations and/or contractual obligations, outline how the company addresses a particular risk. Procedures guide employees on how to comply with policies and adhere to best practices.
Policies & Procedures
A fair, timely and thorough investigation should be conducted in the event you receive credible evidence that misconduct has occurred. FAR 52.203-13 requires companies working on government contracts to timely disclose certain violations of criminal law.
Investigations
Compliance training teaches employees about the policies, laws and regulations that apply to their jobs. Ethics training prepares employees to handle misconduct and ethically ‘gray’ situations.
Training
An ethics program assessment is a way of “auditing” the effectiveness of the ethics program as a whole, or of specific ethics program elements. It can be led by an internal or external team but must be done on a regular basis.
Program Assessment
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