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Creating Ethics and Compliance Programs That Work with Sarbanes-Oxley

BY Bert F. Lacativo
August 01, 2003

Part Two of a Two-Part Article

Last month, we discussed how brightly the spotlight is shining on ethics and compliance programs. We explained that Sarbanes-Oxley has a provision that provides Federal protection for employees of SEC registrants who report wrongdoing to the government and/or law enforcement. The Act has created a situation in which anyone who reports wrongdoing to the government and/or law enforcement is protected from employer retaliation under Federal Statute. And we urged that companies assess the effectiveness of their ethics and compliance efforts.

Having reviewed program design, board of directors and senior management, and employees in last month's article, we continue that theme, concentrating on vendors and customers, the assessment, and ongoing monitoring systems.

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