GOVERNANCE: Better Adherence to Leading Practices for Ethics Programs Could Reduce Company Risks
Our work showed the company’s current ethics-related activities partially align with some leading practices; however, these actions do not, in the aggregate, constitute a comprehensive and effective ethics program necessary to help prevent and detect criminal conduct or other unethical behavior. Without a robust ethics program that is fully in line with these practices, the company remains vulnerable to legal risks from employees’ unethical actions, as well as harm to the company’s reputation. Moreover, taxpayer dollars will remain at risk.
We recommend that the company take several steps to implement a comprehensive ethics program, including setting the management “tone at the top” and establishing an executive steering committee and a full-time program director. Once established, we recommend that the new Program Director coordinate with appropriate stakeholders to implement the critical components of an ethics program, such as defining program roles and responsibilities, implementing a communications plan and training program, and measuring program performance.
In commenting on a draft of this report, the company agreed with two recommendations, partially agreed with a third, and provided information on actions the company plans to take by September 30, 2017.