September 25, 2000 LUncheon Presentation

Characteristics of compliance vs. ethics focused programs.

Compliance

Ethics

- Legally driven

- Mandated

- Measurable

- Top management support

- Administered thru chain of command

- Subject to sanctions

- Values driven/emphasized

- Somewhat voluntary

- Necessity and value challenged

- Many skeptics

- Why me/us attitude

- Difficult to evaluate

Characteristics of compliance vs. ethics focused programs. (continued)

Compliance

Ethics

- Influenced by external forces

- Specified period of applicability in CIA situations

- Reactive

- Usually does not affect all employees

- Internalization difficult

- Management support often difficult

- Proactive

- Permeates organization; when successful can have long-range impact

- Cuts across organizational lines

Evolution of a compliance program presents

great opportunity to develop partnership

between compliance and ethics.

Building the partnership

- Strengthens both functions

- Synergistic affect

- More acceptable to employees

- Involves and touches all employees

Steps in making partnership work; tips for success

- Board and top management involvement

- Separation of compliance and ethics, but with equal access and recognition

- Cooperation/coordination; issue resolution

- Compliance - Quality Mgmt.

- Ethics - Human Resources

- Audit - Security

- Law - Operations

- Training

- Everyone; face-to-face; videos; case studies

- Compliance

- Ethics

- Managers as facilitators

- Incentives for support

- Discipline

- Perseverance

- Reporting problems; guidance; venting

- Measurement and feedback

Advantages of partnership program

- More acceptable

- More sustainable

- Fosters support/participation

- Feel good atmosphere

- Part of culture

"Rules of conduct, whatever they may be,

are not sufficient to produce good results

unless the ends sought are good."

Bertrand Russell