by Joe Murphy
One topic that has always interested me is how one gets a compliance program to reach outside of headquarters and into the field and the business operations. In the environmental compliance and workplace safety areas I believe it is expected that one will have a champion of the program at each location. But in other parts of compliance and ethics it is not as well established. For organizations that want to reach all parts of the organization, one key step is to have compliance and ethics managers in the business units and facilities. For large subsidiaries there may be full time compliance officers. But more common is having someone with part-time responsibility for the program as its local champion and facilitator.
I have found this topic missing in a surprising number of government standards, scholarly articles and even texts in this field. So I have decided to compile a bibliography of sources, for those who would like to learn more about this aspect of compliance and ethics.
Note that while many of the sources in this bibliography can be found through internet searches, there are others that will not show up in such searches (for example, chapters or sections in texts and materials that pre-date the Internet). Also, the searches can be difficult because of the many ways these positions are labeled.
This is a collection of sources on field compliance & ethics managers. The titles for these positions may vary, and include: ethics ambassadors, compliance coordinators, compliance liaisons, compliance champions, compliance and ethics leaders, ethics liaisons, facility compliance officers, business unit compliance officers
Brazil, Administrative Council for Economic Defense (CADE), Guidelines for Competition Compliance Programs 3.2.1.1 Commitment (“If the company is simultaneously active in several countries or economic sectors, then the possibility of designating national and regional compliance leaders should be considered.”)
CEB Compliance and Ethics Leadership Council, Building a Scalable Compliance
Infrastructure: Leveraging A Liaison Network – Additional
Monica Ramirez Chimal, Compliance Ambassadors Wanted! Compliance & Ethics
Professional 26 (Nov. 2020)
Department of Health and Human Services, Office of Inspector General, OIG Compliance Program Guidance for Pharmaceutical Manufacturers, 68 Fed Reg. 23731, 23743 n.14 (May 5, 2003)(“For companies with multiple divisions or regional offices, the OIG encourages coordination with each company location through . . . [communication] with parallel compliance liaisons in each division or regional office, as appropriate.”)
Guendalina Donde, Promoting Ethics on the Front
Line (May 15, 2017; updated Sep. 10, 2020))
Elkem, Elkem compliance champions, (Sept. 3, 2020)
Environmental Protection Agency, Final Policy Statement on Incentives for SelfPolicing: Discovery, Disclosure, Correction, and Prevention of Violations II.B. (b) (Mar. 30, 2000) https://www.federalregister.gov/documents/2000/04/11/00–
8954/incentives–for–self–policing–discovery–disclosure–correction–and–prevention–ofviolations (“assignment of specific responsibility for assuring compliance at each facility or operation”)
Bruno Falcone, Building an effective compliance champion program, Compliance & Ethics Professional 27 (Dec. 2015).
Thomas Fox, The Compliance Champion: Getting People to Solve Problems Without You, (Sep. 13, 2011)
Samantha Greves, Anne R. Harris, Michael Kallens & Courtney Wallize, Ethics Liaison Programs (Oct. 4, 2015)
Todd Haugh, Harmonizing Governance, Risk Management, and Compliance Through the Paradigm of Behavioral Ethics Risk, 21 U. Pa. J. Bus. L. 873, 905-06 (2018)
Jaclyn Jaeger, Building a Compliance Ambassador Network, Compliance Week 42 (June 2019)
Jeffrey M. Kaplan & Joseph E. Murphy, §9:15 Compliance field infrastructure,
Compliance Programs and the Corporate Sentencing Guidelines 449 (Thomson
Reuters; 2017-18 Edition)
Richard P. Kussero, Compliance Liaison
Zachariah Lindon, A different approach to ethics liaison programs, ethikos 1 (May/June 2016).
Joseph E. Murphy, “Facility Compliance Coordinator Position Could Help Ensure that Compliance Program Reaches the Field,” Prevention of Corporate Liability 12 (Dec.
16, 1996)
Joseph E. Murphy, 501 Ideas for your Compliance and Ethics Program: Lessons Learned from 30 Years of Practice 15 (2008).
Matt Silverman, “Championing” Your Compliance Program, Compliance & Ethics
Professional 16 (Nov. 2020)
Roy Snell, Brent L. Saunders, Joseph E. Murphy & Elizabeth Ryan, The Health Care
Compliance Professional’s Manual, Joseph E. Murphy & Debbie Troklus, Compliance Officers and Infrastructure 5-2:9 (Aspen Publ)
Ruth N. Steinholtz & Judith Irwin, Good Practice Guide: Ethics Ambassadors (IBE; 2010)
Ruth N. Steinholtz, Ethics Ambassadors: Getting Under the Skin of the Business,
Business Compliance 16 (03-04, 2014)
University of Denver, Compliance Liaison Overview, (April 16, 2014; last update: June 4, 2020)
Rebecca Walker, Extending the reach of your program: Compliance and ethics liaisons, Compliance & Ethics Professional 21 (Dec. 2014)
Telling people simply to ‘be ethical’ is not enough when values conflict. Loyalty, fairness, honesty, and compassion can point in different directions, and the law exists to help society prioritize
Joe Murphy was building the foundations of compliance before there was a compliance profession to build. Across decades of scholarship, institution‑building, mentorship, and advocacy, he has shaped not just programs
For him, compliance was never just a job. It was a calling, a commitment that shaped how he lived and who he became. Once he committed to something that mattered—to
Retaliation rarely looks like misconduct. It hides in everyday management decisions—changed schedules, missed promotions, quiet exclusions. Managers may see routine actions, but employees experience punishment for speaking up. That gap
Subscribe now to keep reading and get access to the full archive.