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Terms in this set (78)



THE FIVE PRINCIPLES RELATED TO E&C STRATEG, RISK MANAGEMENT, CULTURE, SPEAKING UP, ACCOUNTABILITY


FOUR COMPONENTS OF RISK IDENTIFICATION, OWNERSHIP, MANAGING, MITIGATION


INTEGRITY ALIGNMENT WITH WHAT WE THINK, FEEL, SAY, AND DO


ACCOUNTABILITY IN E&C RELATES TO HOW WE MANAGE INVESTIGATION, BUILD EFFECTIVE PARTNERSHIPS WITH
STAFF AND OTHER AGENCIES


ACCOUNTABILITY IS (4) Holding ourselves and others accountable for success and shortcomings of
our operational activities;
• Adhering to a process of continuous program improvement;
• Using feedback and experience to implement program changes;
• Creating a climate of psychological safety and culture of integrity.


HQP stages UNDERDEVELOPED, DEFINING, ADAPTING, MANAGING, OPTIMIZING


UNDERDEVELOPED STAGE - A new E&C program or an existing one that has not progressed far in
embedding HQP elements. program has adopted few of the leading practices
found in high- quality programs or perhaps even met the minimum standards of
the US Federal Sentencing Guidelines


DEFINING STAGE program that has a few HQP elements, but still lacks many important
attributes.program is established but is not widely embraced by the
organization and operates tactically and not strategically


ADAPTING STAGE A program that contains a number of HQP elements reflecting some important
attributes, but with room to further mature. program is beginning to include
more leading practices of High Quality Programs, but lacks consistency

, MANAGING STAGE An E&C program that can be considered effective or good, but not a "High
Quality Program. the program is mapping more consistently to business and
operational needs and discussions. Leaders in the organization are generally
demonstrating ethics-related actions; employees are comfortable raising issues
without fear of retaliation, and the organization demonstrates accountability in
a robust investigatory process that is fair, neutral and consistent.


OPTIMIZING STAGE An E&C program that contains the majority of, if not all, HQP elements.the vast
majority of HQP leading practices are demonstrated and embedded
throughout the organization across all principles. The organization shares its
knowledge externally and is generally viewed as having a High Quality E&C
program within and outside of its industry.


HQP REGRESS IN MATURITY DUE TO (4): Change of leadership and focus
• Reduction in staff and resources
• Failure to adopt a mindset and program of continuous improvement
• Complacency


CECO STANDS FOR CHIEF ETHICS AND COMPLIANCE OFFICER


CECO ADDS VALUE BY: -ARTICULATING THE ORG VISION FOR E&C AND DEVELOPS STRATEGY
-ASSISTS LEADERSHIP
-MONITORS AND EVALUATES E&C PROGRAMS
-DEMONSTRATES ORG COMMITMENT TO INTEGRITY
-MITIGATES SANCTIONS BY E&C INCIDENTS


E&C 2019 DOJ GUIDANCE FACTORS (3) 1. Is the program risk-centric
2. Is the program well-designed
3. Has the program been demonstrated to work effectively


SANCTIONS ARE MITIGATED BY showing evidence of visible and consistent efforts to create an organizational
culture that supports and encourages ethics and compliance


ROLE OF THE CHIEF ETHICS AND COMPLIANCE to ensure that E&C is central to business strategy and activities are consistent
OFFICER with the organization's values when we execute on strategy and achieve results


ENVIRONMENT INCLUDES (3) • Organizational culture, climate and conduct;
• Business, industry and regulatory context;
• A robust network within and outside of the E&C practice.


AN AFFECTIVE CODE -REINFORCED THROUGH TRAINING AND COMMUNICATION
-INCLUDES FAQS AND CASE STUDIES
-EASY TO FOLLOW AND WRITTEN AT AN APPROPRIATE READING LEVEL
-COMMUNICATED THROUGH COUNTRY-SPECIFIC TRANSLATIONS
-RISK IDENTIFIED THROUGH RISK ASSESSMENT
-FEEDBACK FROM STAKEHOLDERS


USER-RELATED METRICS FOR A CODE (3): • The frequency of access to the Code compared to other E&C resources;
• Relevance of the Code to the challenges faced by users;
• Evolving access platform preferences among employees across regions and
demographics.

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