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Source: Murphy, J.E. 2010. “A Compliance & Ethics Program on a Dollar a Day: How Small Companies Can Have Effective Programs,” Society of Corporate Compliance and Ethics, Minneapolis, MN, www.corporatecompliance.org, August.
First, a comment about the title of this report. It is “catchy,” but not credible, from the perspective of business or government personnel who face many and varied “pulls” on the use of his or her time or when viewed by a business person who must deal with the “bottom line.” I say this because, while the document carefully estimates expenses, it does not account for labor! — a major cost. In fairness, on page 28 of the 29 page document, the author asks “where will you get the time?” A critical question!
My second comment, which is much more positive, pertains to the content, more specifically, the many suggestions for developing a “compliance and ethics program.” The suggestions are organized under the following 11 elements, each of which is listed here in summary form: 1) Risk assessment, 2) Having standards/procedures, 3) Managed by a senior person, 4) Care in hiring/promoting, 5) Systems for dealing with third parties, 6) Communication with employees, 7) Monitoring, 8) Discipline, 9) Consistent incentives and appraisals, 10) Quick response, and 11) Consistency with industry practice. Each of the preceding 11 elements is detailed in the document – lots of “meat” here.
Closing Thought: Like any other important and worthwhile organizational effort, a compliance and ethics program requires commitment from the top and we know that those commitments cost orders of magnitude more than “a dollar a day.”
Might you want to arrange an in-house ethics presentation? For example, a company-wide 60 to 90 minute webinar or an on-site half-day or more workshop? A program like this is likely to help engineers and other licensed professionals meet their continuing education requirements. To discuss your need, please contact me at stu-walesh@comcast.net or call me at 219-464-1704.
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