The Board’s Role In Curbing Ethical Issues

Business Ethics
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What are some of the big initiatives that you guys have going on?

One of the things that we have tried to do is to not only do this research to make sure that people understand the importance of ethics and compliance programs, but to help provide guidance to business leaders that want to actually move in that direction. So we’ve been working on a framework that defines what does it look like when you have a high-quality ethics and compliance program. Right now, we’re working on a very extensive measurement framework so that companies can look at not only do we have a program in place, but how are we doing with it? How do we measure the success of it? So that’s a big thing.

We are trying to do more in our events and in our certification efforts, to help our practitioners and our profession to think, not only about how do we make sure we’re complying with the law, but what is our responsibility to think ahead about the emerging issues, and also making sure that our companies are acting responsibly in the work that they do.

We’re also doing some work around predictive analytics. I think that’s sort of the new frontier for ethics and compliance as it is with a lot of other functions in an organization. But increasingly, there is interest by companies to mine the data that they have to get a sense of, is it possible to figure out the times when certain portions of our business are higher risk for problems, and to what extent can we identify those metrics and use them to monitor our organization. So we’re leading a research effort to try to figure that out.

You bring up an interesting point. Do you think it’s really top of mind these days, you know, more than ever, that organizations are really looking out for this sort of thing, just because of all these high-profile cases of misguided ethics and bad culture?

I think it’s top of mind for large global organizations with a global footprint, certainly, because they can’t avoid it in part, but also because we’ve certainly seen lots of instances where companies have become the poster children of what happens when you don’t really keep it top of mind. The challenge is bigger, I think, well…and that’s a huge challenge. I don’t want to diminish that. But it’s probably not on the forefront as much for small and medium-sized enterprises, unless they happen to be doing business with the government or sub-contracting with a large organization that requires them to have a program and then it’s harder.

But we’ve also seen that the majority of enforcement that happens, at least by the DOJ and things like False Claims Act violations, tends to be with small and medium-sized enterprises. So they shouldn’t be dismissing the risk. It should be top of mind. It’s just generally not…there’s less of a structure so it’s harder to focus on.


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