Joe Murphy – Compliance & Ethics Professional – September/October 2013
One of the most common questions today in our field is, “How do I measure our compliance and ethics program?” Usually when we think of this, we think of trying to determine how effective the program is: Does it really work to prevent and detect misconduct and does it reach your employees? Those are certainly important questions and ones that you should ask. But there is also another important measure of any program— in fact, the measure seen in the recent Morgan Stanley case where a company walked away from possible prosecution because of its strong program:
Would your program convince an outside, skeptical regulator or prosecutor?
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