
Standards for waivers of conflicts of interest
While some organizations bar conflicts of interest in all cases, many opt for allowing COIs to exist where appropriate. But how should appropriate be defined for these purposes?
by Rebecca Walker
I just got started working with a client on planning their annual Compliance & Ethics Week, which will likely roll out in October. I must admit, when I first heard the term “Compliance and Ethics Week,” many years ago, I was skeptical. The SCCE launched the initiative way back in 2005 (nearly twenty years ago!) as a tool for companies to use to increase recognition and awareness of companies’ C&E programs. The concept seemed just a tad too gimmicky to be effective.
Turns out, once again, I was wrong. Clients’ early efforts to use a C&E Week in their programs did sometimes sputter or even fall flat, but we have come very far in the nearly twenty years since the SCCE introduced us to C&E weeks. And many other compliance-related functions (Privacy Week, Cybersecurity Week, Workplace Safety Week) have jumped on the bandwagon.
The success of a good C&E Week campaign lies in the variety of ways that organizations communicate and the concentrated nature of the communications. For some organizations, over the course of one week, the C&E team will send out videos, emails, and posters; manage contests that include fun (yes, they can be fun!) prizes; set up tables that contain C&E goodies at appropriate sites; host live presentations at a variety of sites; host an outside speaker at an organization-wide town hall; and provide fresh material on the C&E area of the intranet. C&E weeks may also (for lucky organizations with a good budget!) include site visits by the C&E team to locations that do not typically get enough “face time” with C&E staff.
The very best C&E weeks often involve significant participation by senior leadership. A program that I assessed last year utilized live presentations by the executive leadership team and the audit committee chair regarding the importance of business ethics on day 1, and then live presentations by segment leaders to each segment on day 5. Although the assessment occurred several months after that organization’s C&E Week, it was the topic most mentioned by interviewees. The best-reviewed of such presentations typically involve a testimonial by a senior leader regarding their own experience with an ethical dilemma. It seemed to be extremely effective at convincing employees of senior leadership’s commitment to compliance. And equally effective at convincing senior leadership of the value of their participation in the compliance program.
If your organization does not yet use this tool, consider it. And for those of you worried about the potential of C&E Week being perceived as gimmicky, I can assure you that I have heard positive reviews by the most skeptical of CEOs, audit committee chairs and employees.
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