Law.com Subscribers SAVE 30%

Call 855-808-4530 or email [email protected] to receive your discount on a new subscription.

The Truth Can Hurt Even More When It's Too Late

By Jim Deupree
February 06, 2004

An industry-leading company recently commissioned two outside firms to perform an objective assessment of its corporate ethics program. Each assessment was extensive, involving interviews with anyone who wanted to talk, and people selected by the teams, ranging from middle management to the CEO. Collectively, the two assessments had interviews or focus groups with over 1000 people at every major location. This probably represents the most comprehensive assessment of ethics program effectiveness factors completed in 2003. (One of the assessments was completed by the law firm of Paul, Weiss, Rifkind, Wharton & Garrison, LLP. The assessment team was led by former Senator Warren Rudman, and their findings were published on Nov. 3, 2003. The other assessment was completed by Ethical Leadership Group, and their findings were published on Oct. 23, 2003.)

A number of their findings would allow any company to conclude that its ethics program was excellent, and report, “We've got ethics covered” to its board. The findings included:

  • The company had a Vice President for Ethics and Business Conduct, an Ethics and Business Conduct committee, an Ethics Process Council and designated ethics personnel in each of the business units.
  • Ninety-eight percent of employees interviewed recalled receiving ethics training during the past year.
  • An ethics hot line had been established, and 98% were also aware of its existence.
  • Ethics posters were prominently and widely displayed in the workplace.

Fundamental Issues

Read These Next
The DOJ's Corporate Enforcement Policy: One Year Later Image

The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.

The Bankruptcy Hotline Image

Recent cases of importance to your practice.

Use of Deferred Prosecution Agreements In White Collar Investigations Image

This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.

How AI Has Affected PR Image

When we consider how the use of AI affects legal PR and communications, we have to look at it as an industrywide global phenomenon. A recent online conference provided an overview of the latest AI trends in public relations, and specifically, the impact of AI on communications. Here are some of the key points and takeaways from several of the speakers, who provided current best practices, tips, concerns and case studies.

New York's Latest Cybersecurity Commitment Image

On Aug. 9, 2023, Gov. Kathy Hochul introduced New York's inaugural comprehensive cybersecurity strategy. In sum, the plan aims to update government networks, bolster county-level digital defenses, and regulate critical infrastructure.