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Purposes Served by Ethics Reporting Mechanisms

Alice Peterson
SAI Global Compliance



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Ten Features of Effective C&E Assessments: Part 2

Jeff Kaplan | Kaplan & Walker, LLP

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SAI Global Compliance

SAI Global Advisors

SAI Global's advisors include our Law and Ethics Advisors, practicing lawyers and ethicists who are subject matter experts in fields of particular relevance to compliance and ethics programs, and others in the field of ethics, governance, risk management and compliance. They share their viewpoints about emerging issues, items in the news, and thoughts to ponder on this Website. We look forward to reading your comments in response.

Andy Wyszkowski,

Global Head, Compliance and Publishing

Purposes Served by Ethics Reporting Mechanisms

by Alice Peterson, Jun 29, 2009

The key purpose served by effective confidential employee reporting structures is, by and large, the same as the key purpose of good governance in general:

  • Achievement of the organization’s mission
  • Strong reputation
  • Increased transparency and accuracy of financial reporting
  • Enhanced investor and patron confidence
  • Mitigated risk of adverse volatility in public companies’ security prices
  • Reduced probability of misappropriation of assets
  • Access to capital
  • Fewer adverse findings by auditors and regulators
  • Lower litigation risk and experience
  • Reduced insurance costs
  • In addition to Sarbanes-Oxley, there are a number of laws that stipulate requirements for hotlines.

    Read the rest of this entry »

    Ten Features of Effective C&E Assessments: Part 2

    by Jeff Kaplan, Jun 22, 2009

    Part 2

    A second feature of effective C&E risk assessments concerns the nature of the information that one seeks through the process. That is, while a traditional risk assessment generally attempts to develop information about risk impact, information about the causes of risks may in fact be more useful. (Risk likelihood information is a focus of both traditional risk assessments and what I am calling in this series effective risk assessments.)

    Of course, knowing about impact is still important. But unlike risk likelihood - where a broad data gathering effort may be necessary to gain a real understanding - generally the law department is a sufficient source of information on impact. For instance, one doesn’t need to conduct a survey or a lot of interviews to know that the impact of a competition law violation could be high.

    Read the rest of this entry »

    Ten Features of Effective C&E Risk Assessments

    by Jeff Kaplan, Jun 01, 2009

    The 2004 revisions to the Corporate Sentencing Guidelines codified what was already well known to C&E practitioners: that risk assessment should be the foundation of an effective C&E program.

    But what exactly should a C&E risk assessment entail? In this series of postings, I’ll explore what I believe are ten features of effective risk assessment, which are:

  • Determine where to focus one’s efforts
  • Assess the causes of risk
  • Educate interviewees so they can contribute in a meaningful way
  • Measure net, as well as gross, risk
  • Use your current risk assessment to lay the groundwork for future ones
  • Assess ethics, as well as compliance, risks
  • Give sufficient attention to public information
  • Use assessments to help one’s board oversee the program
  • Assess third-party risks
  • Assess risks from the economic downturn
  • Read the rest of this entry »





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