Perspectives of Chief Ethics and Compliance Officers on the Detection and Prevention of Corporate Misdeeds: What the Policy Community Should Know

By Michael D. Greenberg | Go to book overview

APPENDIX C: INVITED PAPERS FROM PANEL PARTICIPANTS

From Enron to Madoff: Why Many Corporate Compliance and Ethics Programs Are
Positioned for Failure

Donna Boehme, Compliance Strategists, LLC
Remarks presented on March 5, 2009


Introduction: “Where Was the Ethics Officer”?1

With the wreckage of the first generation of Enron-type corporate scandals in the rear view mirror, and the chaos of Madoff and the subprime meltdown now all around us, commentators are asking “Where were the ethics officers?” and “Are corporate compliance and ethics programs just window dressing?” These are fair questions, given that in the 18 years since the 1991 promulgation of the U.S. Organizational Sentencing Guidelines (which set out the roadmap for companies to detect and prevent wrongdoing),2 several studies have indicated that little progress has been made,3 and recent events in the corporate world suggest that effective mechanisms to prevent corporate misconduct are lacking. This paper sets out a response to these two questions from some leading practitioners in the field of corporate compliance and ethics. This paper also suggests a path forward, moving beyond the sometimes unrealistic assumption of policymakers, boards and management that integrity and compliance can be achieved simply by establishing basic elements such as a formal code of conduct, an “ethics officer,” a training program, monitoring, and/or an employee helpline, and then expecting that good results will necessarily follow. In short, we believe that it is time for companies to get serious about corporate culture, accountability, compliance and ethics, and that the key initial step in achieving this involves the creation of a C-level, empowered compliance and ethics officer: someone with the experience, positioning, mandate and clout to actually make things happen in the organization.

1 For convenience, the term “ethics officer” is intended to encompass the role of the chief compliance and ethics officer, in its many variations.

2 The guidelines, including the 2004 amendment, are available at http://www.ussc.gov/guidelin.htm. The amendment became effective on November 1, 2004.

3 The Ethics Resource Center’s 2007 National Business Ethics Survey, based upon interviews with 2,000 employees at a broad range of public and private U.S. companies, found “little if any meaningful reduction in the enterprise-wide risk of unethical behavior at U.S. companies.” ERC Press Release, November 28, 2007, available at http://www.ethics.org/about-erc/press-releases.asp?aid=1146.

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