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Key results from Ethics & Compliance Initiative’s Global Business Ethics Survey:

22% of employees have felt pressure to compromise standards
33% observed misconduct
59% of those that observed misconduct went on to report it
36% experienced some form of retaliation for reporting it

What it means for organizations: Invest sufficient resources to monitor behavior at every operating location and to develop ethics and compliance (E&C) programs designed around a common code of conduct. Include strategies to protect against retaliation – such as ready-access to an ethics hotline with a clear non-retaliation policy.

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What topics are covered by ethics codes? A part of ethics training? Reported in ethics hotlines? Here’s a list of the most common ethics concerns:

– Accounting, internal controls, auditing matters
– Workplace issues: substance abuse, FLSA, FMLA
– Environmental, health, safety concerns
– Falsification of documents or records: fabricating, altering, destroying
– Discrimination: age, disability, genetic information, national origin, pregnancy, race/color, religion, sex
– Harassment: written, verbal, physical
– Violence in the workplace
– Conflict of interest: gifts receiving
– Breach of confidentiality: HIPAA, IP, trade secrets, trademarks, copyrights
– Theft, embezzlement
– Improper use of property: vandalism, destruction
– Improper use of computers, email, Internet
– Unfair competition: US Antitrust, bid-rigging
– Bribery: FCPA, gifts giving
– Insider-trading
– Money-laundering
– Corruption: kickbacks
– Violation of export control laws: ITAR, EAR
– Illegal political contributions
– General misconduct
– Company policy violations
– SOP violations
– Retaliation

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GOVERNANCE

It is the responsibility of the Audit Committee to establish policies and practices to prevent financial fraud; monitor internal control process; arrange for a standard ‘whistle-blowing’ procedure.

Whistle-blowing policies and guidelines should be implemented within organizations and companies of any size, and whether publicly or privately owned, to reinforce ethical behavior among staff and employees.
Whistle-blowing policies are generally included in an organization’s code of ethics or code of conduct.

EMPLOYEES

One of the most important reasons to have an Employee Handbook is to ensure that staff members understand the organization’s standards of conduct / code of ethics.

Ethics Code: generic template/outline; how to implement an ethics code; advice on developing an ethics code; links to ethics code examples by industry.

Check out other resources from B Corp that “help companies improve their social and environmental performance.”

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December 1 commemorates “the beginning of the modern civil rights movement in the United States. That was the day [in 1955] when an unknown seamstress in Montgomery, Alabama refused to give up her bus seat…” (More about Rosa Parks.)

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Just as important as the ethics hotline, is your internal procedure on incident report handling and the investigation process. Follow these related links:

  • Investigative Tips for the Non-investigator, by BDO Consulting
  • The Essential Guide to Workplace Investigations, by Lisa Guerin, J.D.
  • Investigations: 4 Tips to Do Them Right, by BLR
  • Conducting Effective Harassment Investigations, by J.J. Keller’s Prospera
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    “A Compliance & Ethics Program on a Dollar a Day: How Small Companies Can Have Effective Programs,” written by Joseph E. Murphy, JD, CCEP, is available on The Society of Corporate Compliance and Ethics (SCCE) homepage. Also check out MYECCHO – the affordable ethics hotline and case management system for small companies.

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