No code? No training? How can that be a compliance program?

Joe Murphy – Compliance & Ethics Professional – September 2014


I have seen writers, professors, and commentators of all kinds confuse codes of conduct with compliance programs. I have also seen them treat training as if that were a compliance program. Many seem to think that of the seven Guidelines steps, all you need is parts of two of them. Since so many seem to think you can have a program by only touching two of the seven elements, suppose we have a program with ve of the steps, but just omit a code and training?

Many would say this couldn’t possibly work. But consider some possibilities. Start with incentives: Have all management assessments include a strong element of compliance. You can’t get a bonus or promotion unless you demonstrate a serious commitment to compliance and ethics. No code, no company training, but real money at stake. Employees have a motive to ask their bosses what they should do. They go online to nd out. The company has a risk assessment they use for guidance.

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