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Establishing Ethics and Compliance Policies

April 02, 2012 | Comments: 0 | Views: 175

"Standards, Policies, and Procedures"

As a compliance professional you're charged with, among other things, setting standards and creating policies and procedures for your organization's ethics and compliance (E&C) program.

Let's address the easiest of these - compliance policies - first.

Really there's just one policy when it comes to compliance:

"Our policy is that you must comply at all times with all applicable laws and regulations. Failure to do so will result in disciplinary action, and may result in termination of employment and possible criminal prosecution."

There. If you're currently working on creating your organization's compliance policies, take the rest of the day off.

Ethics policies, on the other hand, aren't quite that easy. They're not difficult... they're just not that easy.

See, most ethics codes read pretty much the same. There's usually a preamble from the CEO that says things like "... we are committed to the highest ethical standards", "honesty and integrity in everything we do", "respect and trust", "fairness, responsibility, blah blah blah..."

Then there's the list of things Thou Shalt Do and Not Do: bribes, conflicts of interest, sexual harassment, privacy, gifts, discrimination, safeguarding company property and assets, retaliation... etc.


It makes me a little uncomfortable when I see consultants charging fees for helping to write a code of ethics for a company. That's like a garage charging you money to change the air filter in your car. 17 bucks for lifting the cover and dropping it in?! C'mon. If you can open the box the filter is sold in, you can change it yourself for free.

The hardest part about writing an ethics code is deciding whose code you're going to copy. After all, isn't that what the phrase "best practices" implies? Figure out who's done the best job of creating one of these things and just do what they do.

Oh sure, your ethics code should reflect the unique character of your company... but really, who cares. Certainly not your employees. They don't need some document to tell them how everyone should behave. They come to work every day and they see how everyone actually behaves. And that speaks louder than your code of ethics ever could.

Glib? Irresponsible? Dismissive? Yup. I did it on purpose, to offer a little perspective. The truth is, this is likely the attitude your employees have about the E&C program you're working so hard to embed.

So what's the take-away here? When it comes to your standards and policies, don't settle for "best practices". Best practices are what everyone is doing. Make your standards and policies better. Spend less time looking around to see who's on the cutting edge and more time honing the edge.

John Puckett

Source: EzineArticles
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