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Bernard Gutierrez & Abbas Al Abbas 
Internal Audit/Ethics and Compliance Professionals 
Ethics in Business 
The Need to Establish an Ethics & Compliance Program 
20 February 2012
Objectives 
“Ethics” 
 What is it anyway?? 
 Why it is important in organizations 
Importance of leadership and culture 
Organizational challenges and safeguards 
Roles of ethics and compliance officers
Ethics 
A concept of right and wrong 
conduct beyond legal compliance 
Ethical principles are implicit contracts that 
represent who you are and what you stand 
for—what your constituents expect to rely on 
Michigan Business School Guide to The Ethical Challenge, 
How to Lead with Unyielding Integrity
Why is Ethics Important in Organizations? 
Character and ethical behavior in 
organizations affects: 
 Attendance 
 Safety 
 Quality 
 Productivity 
 Loyalty 
 Security 
 Profitability 
 Reputation
Why Should Organizations Behave Ethically? 
 Prevent harm to others, avoid 
reputational harm and reduce 
potential liability 
 Fulfill public expectations and 
improve external relations 
 Protect organization from others 
(employees, competitors, etc.) 
 Improve workforce productivity 
but protect employees if needed 
from their employers 
 Promote personal morality
Reasons for Ethical Problems in Organizations 
 Personal Gain and Selfish Interest 
 Competitive Pressure on Finances 
 Organizational Goals vs. Personal Values
Ethics and Compliance Risks in the Company 
 Cash on hand funds are misused, 
mishandled, and unrecorded 
 Online payment facility can edit bank 
account details 
 Weak organizational and process 
structures 
 Workplace discrimination 
 Disgruntled employees 
 Tone-at-the-top/corporate culture 
 Bribery 
 False financial reporting information 
 Poor communication practices
Impact of the Individual Leader/Manager 
“The behavior and ethical attitude 
of an employee’s boss 
is seen as the most important factor 
determining whether the 
employee will behave unethically on the job” 
(Liebig, J.E. 1990)
Organizational Safeguards 
BBeesstt PPrraaccttiicceess 
 Leadership/Open door policy 
 Ethics and compliance officers 
 Ethics committee 
 Code of conduct 
 Discussion forums 
 Conflict of interest assessments 
 Periodic risk assessments 
 Ethics and compliance training 
 Help line 
 Recognition effort 
 Corporate citizenship
Organizational Safeguards 
Fraud Prevention - Code and PPoolliiccyy JJuussttiiffiiccaattiioonn 
When a strong Code of Conduct was in place: 
The median fraud losses were reduced by 46%* 
and 
The duration of the fraud scheme was reduced on 
average by 37.5%* 
When an anti-fraud policy was in place: 
The median loss related to fraud was reduced by 40%* 
and 
The average duration of a fraud scheme was reduced by 
28%* 
Source: 2010 ACFE (Association of Certified Fraud Examiners) 
Report to the Nations on Occupational Fraud and Abuse
Ethics and Compliance Program 
Corporate Ethics & Compliance Program 
 Do the Right Thing: Principles of Business 
Conduct 
 Ethics & Compliance Officers 
 Risk Assessment 
 Continuing Education – Awareness Campaign 
 Integrity Hotline (Confidential and/or 
Anonymous) 
 Integrity in Action Awards 
 Organizational Leadership
Ethics and Compliance Program 
What Will Ethics & Compliance Officers Do? 
 We will help establish codes of ethics, and require all 
employees to read, understand, and sign it. 
 Examine the stated values, mission, and goals of the 
organization and determine if the organization’s behavior 
supports these statements 
 Conduct anti-fraud, compliance and ethics orientation and 
awareness trainings. 
 Assess risks and correct inconsistencies in implementing 
disciplinary actions. 
 We will also recommend to reward employees’ ethical 
conduct. 
 Implement an anonymous and/or confidential “hotline” as 
an effective misconduct reporting mechanism. (Occupational 
frauds are much more likely to be detected by tip than by any other means. – ACFE 2010)
Ethics and Compliance Program 
What Will Ethics & Compliance Officers Do? (cont.) 
 Establish and communicate a whistleblower protection 
policy to report misconduct in the workplace. 
 Create a compliance program based in institutional and 
personal values 
 Review and amend the language of the Company 
policies, communications, training to incorporate ethics & 
values 
 Follow through with reports of misconduct and promote 
effective internal controls. 
 Undertake investigations into specific employees or 
activities to confirm that they conform with the Company’s 
ethical guidelines 
 Help management create a culture of doing the right thing.
Ethics and Compliance Program 
Implementation 
Standards 
Education 
Resources
Thought for the Day 
All that is necessary for the 
triumph of evil is that good 
men [people] do nothing. 
Edmund Burke 
Irish orator, philosopher, & 
politician (1729 - 1797)

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Why is Ethics and Compliance important

  • 1. Bernard Gutierrez & Abbas Al Abbas Internal Audit/Ethics and Compliance Professionals Ethics in Business The Need to Establish an Ethics & Compliance Program 20 February 2012
  • 2. Objectives “Ethics”  What is it anyway??  Why it is important in organizations Importance of leadership and culture Organizational challenges and safeguards Roles of ethics and compliance officers
  • 3. Ethics A concept of right and wrong conduct beyond legal compliance Ethical principles are implicit contracts that represent who you are and what you stand for—what your constituents expect to rely on Michigan Business School Guide to The Ethical Challenge, How to Lead with Unyielding Integrity
  • 4. Why is Ethics Important in Organizations? Character and ethical behavior in organizations affects:  Attendance  Safety  Quality  Productivity  Loyalty  Security  Profitability  Reputation
  • 5. Why Should Organizations Behave Ethically?  Prevent harm to others, avoid reputational harm and reduce potential liability  Fulfill public expectations and improve external relations  Protect organization from others (employees, competitors, etc.)  Improve workforce productivity but protect employees if needed from their employers  Promote personal morality
  • 6. Reasons for Ethical Problems in Organizations  Personal Gain and Selfish Interest  Competitive Pressure on Finances  Organizational Goals vs. Personal Values
  • 7. Ethics and Compliance Risks in the Company  Cash on hand funds are misused, mishandled, and unrecorded  Online payment facility can edit bank account details  Weak organizational and process structures  Workplace discrimination  Disgruntled employees  Tone-at-the-top/corporate culture  Bribery  False financial reporting information  Poor communication practices
  • 8. Impact of the Individual Leader/Manager “The behavior and ethical attitude of an employee’s boss is seen as the most important factor determining whether the employee will behave unethically on the job” (Liebig, J.E. 1990)
  • 9. Organizational Safeguards BBeesstt PPrraaccttiicceess  Leadership/Open door policy  Ethics and compliance officers  Ethics committee  Code of conduct  Discussion forums  Conflict of interest assessments  Periodic risk assessments  Ethics and compliance training  Help line  Recognition effort  Corporate citizenship
  • 10. Organizational Safeguards Fraud Prevention - Code and PPoolliiccyy JJuussttiiffiiccaattiioonn When a strong Code of Conduct was in place: The median fraud losses were reduced by 46%* and The duration of the fraud scheme was reduced on average by 37.5%* When an anti-fraud policy was in place: The median loss related to fraud was reduced by 40%* and The average duration of a fraud scheme was reduced by 28%* Source: 2010 ACFE (Association of Certified Fraud Examiners) Report to the Nations on Occupational Fraud and Abuse
  • 11. Ethics and Compliance Program Corporate Ethics & Compliance Program  Do the Right Thing: Principles of Business Conduct  Ethics & Compliance Officers  Risk Assessment  Continuing Education – Awareness Campaign  Integrity Hotline (Confidential and/or Anonymous)  Integrity in Action Awards  Organizational Leadership
  • 12. Ethics and Compliance Program What Will Ethics & Compliance Officers Do?  We will help establish codes of ethics, and require all employees to read, understand, and sign it.  Examine the stated values, mission, and goals of the organization and determine if the organization’s behavior supports these statements  Conduct anti-fraud, compliance and ethics orientation and awareness trainings.  Assess risks and correct inconsistencies in implementing disciplinary actions.  We will also recommend to reward employees’ ethical conduct.  Implement an anonymous and/or confidential “hotline” as an effective misconduct reporting mechanism. (Occupational frauds are much more likely to be detected by tip than by any other means. – ACFE 2010)
  • 13. Ethics and Compliance Program What Will Ethics & Compliance Officers Do? (cont.)  Establish and communicate a whistleblower protection policy to report misconduct in the workplace.  Create a compliance program based in institutional and personal values  Review and amend the language of the Company policies, communications, training to incorporate ethics & values  Follow through with reports of misconduct and promote effective internal controls.  Undertake investigations into specific employees or activities to confirm that they conform with the Company’s ethical guidelines  Help management create a culture of doing the right thing.
  • 14. Ethics and Compliance Program Implementation Standards Education Resources
  • 15. Thought for the Day All that is necessary for the triumph of evil is that good men [people] do nothing. Edmund Burke Irish orator, philosopher, & politician (1729 - 1797)

Notas del editor

  1. Also can be the determinant for employees on whether the company is ethical
  2. Working together