Benchmarking Ethics and Compliance Programs

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One of the questions asked most frequently by those involved in corporate ethics responsibility is "How are we doing?" The question raised is how an organization stacks up in comparison with what it should do. Intended to form the basis of best practices in ethics and compliance, Foundation Guidelines "Red Book": Application Draft, April 2005, is an online document published by the Open Compliance and Ethics Group (OCEG). This framework document, available at www.oceg.org, details the essential components of an integrated compliance and ethics program and is intended to provide guidelines and benchmarks for:

* Integrated Governance, Compliance, Risk Management, and Ethics

* Mission, Vision, Values

* Compliance and Ethics Programs

* Whistleblower Hotlines

* Codes of Conduct/Ethics

* Compliance and Ethics Training Programs

* Program Audit, Assessment, and Benchmarking

Publication of the OCEG guidance is especially timely considering that the U.S. Sentencing Commission raised the bar on ethics and compliance programs last year by upgrading the necessity for organizations to monitor and oversee the effectiveness of their program to the board of directors level. The Sentencing Commission amendment applies to …