Effective Ethics Program

Corporate Compliance & Ethics Week 2015 begins on November 1 this year. The Society of Corporate Compliance and Ethics (SCCE) made the change from prior years, when it was celebrated in May, to better align with the anniversary of the implementation of the Federal Sentencing Guidelines (November 1, 2004).  However, states the SCCE, the week “will still serve to highlight the importance of ethics and compliance in every workplace.”

During Corporate Compliance & Ethics Week, many organizations engage in a variety of educational and other activities designed to focus awareness on various aspects of their compliance and ethics culture and initiatives.

This year’s theme—“Speak Up…We’re Listening”— offers many possibilities

For example, organizations that have ethics hotlines can offer the kinds of activities highlighted last year in the “Promote Hotlines during Ethics Week” blog post. The SCCE provides a number of examples and resources for organizations to use at its website; see the link below.

This year’s compliance and ethics week begins on the anniversary of the Federal Sentencing Guidelines, offering an excellent opportunity to discuss the implications of the guidelines, especially the organizational sentencing guidelines, with board members, senior leaders, and managers at all levels, in addition to all other employees.

The Federal Sentencing Guidelines were developed as a way to reduce sentencing disparity and to prevent crime. On November 1, 2004, an amendment to an earlier version of the guidelines introduced elements of importance to all organizations today. The amendment described detailed elements of an effective compliance and ethics program, expressly joined Ethics and Compliance functions, emphasized the importance of organizational culture, emphasized the importance of risk assessments, and more (Debold and Cooper Grilli, 2015).

An effective compliance program must adhere to the seven minimum requirements identified in the organizational sentencing guidelines and must promote ethical conduct and an organizational culture that encourages a commitment to compliance with the law. The seven requirements are:

  1. Establish standards and procedures to prevent and detect criminal conduct;
  2. Ensure that the company’s governing authority (the board, top management, high level personnel) exercises reasonable oversight of those standards and procedures;
  3. Make reasonable efforts to keep individuals whom organizations knew or should have known have engaged in illegal activities or conduct inconsistent with an effective program out of key positions;
  4. Communicate standards and procedures by training directors, employees and, as appropriate, agents, and by other means;
  5. Monitor and audit the program to detect criminal conduct, evaluate the program periodically, and  have and publicize a system for reporting suspected violations and seeking guidance;
  6. Promote and consistently enforce the program through appropriate  incentives and appropriate discipline; and
  7. After criminal conduct is detected, take reasonable steps to respond appropriately and  prevent further criminal conduct, including necessary modifications to the ethics and compliance program.

This year’s “Speak Up…  We’re Listening” theme, combined with a focus on the seven requirements for an effective compliance program, offers organizations a strong framework within which to celebrate Corporate Compliance and Ethics Week 2015.

Ethical Advocate provides comprehensive ethics and compliance solutions, including ethics and compliance training and confidential and anonymous incident reporting systems, to millions of users in all sectors.  Please contact us for more information.


Debold, David and Kathleen Cooper Grilli. “A Basic Introduction to the Organizational Guidelines.” Presentation at the Annual National Seminar, New Orleans, LA,September 18, 2015. http://www.ussc.gov/sites/default/files/pdf/training/annual-national-training-seminar/2015/intro-org-gl_slides.pdf


SCCE. “Corporate Compliance & Ethics Week,” webpage. http://www.corporatecompliance.org/Products/CorporateComplianceEthicsWeek.aspx

United States Sentencing Commission website. http://www.ussc.gov/