by Adam Balfour
1. Acting within the law and leading with integrity.
2. Having a clear understanding of the ethics and compliance program and how senior leaders play a critical role in making the program work in practice.
3. Setting the right tone for the organization and making sure the organizational values and standards are followed in practice (especially, and visibly, by them).
Doing these things will also keep CEOs out of prison.
If you ever hear your CEO tell you it is your job to keep them out of prison (thankfully I have never found myself in that position), you need to recognize it as a red flag. Unless your CEO is someone like Elizabeth Holmes or Sam Bankman-Fried, this type of comment does not necessarily mean that your CEO is doing things they should be in prison for. Instead, it likely indicates that the CEO doesn’t fully understand the value of an effective compliance program or the tone they need to set for the organization.
Effective ethics and compliance programs will help keep CEOs out of trouble, and they also offer a lot more value than that. ceos are under huge pressure to deliver results – effective ethics and compliance programs are pro-business and have been repeatedly shown to help both top line and bottom line growth. leaning into, and leading with, integrity will help ceos and organizations succeed.
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In our years of assessing compliance and ethics (C&E) programs, my partner Jeff Kaplan and I have pinpointed several key attributes that we consider essential to an effective program, including