Alice Peterson's Archive

Thankfully the number of extremists who think Tone at the Top is all you need to achieve an ethical and compliant culture is ebbing. But they are out there. A board member (and former CEO) said to me last year, “everything I need to know about business ethics I learned at my mother’s knee.” I commented that his mother was indeed prescient to have explained pretexting to him oh so many years ago.

Let’s face it. Tone at the Top means very different things to different people. There’s strong and sincere walk-the-talk and be-accountable tone, and then there’s read-the-speech-someone-wrote-for-me (this time, with feeling) tone. It’s the difference between a finely tuned orchestra tone and dial tone.

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Finding out about wrongdoing is a great start. But unless disciplined processes are employed for tracking, following up, and acting on the information, just knowing about the wrongdoing has limited value. These processes should include how to access the data and who should handle ethics or risk cases.

How to access the data: By linking the risk issues into a software-as-a-service-based case management system, those handling cases can access a secure case database from wherever they are in the world and take the appropriate next steps.

Who should handle ethics or risk cases: There are three key items to consider when making this decision.

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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:

In addition to Sarbanes-Oxley, there are a number of laws that stipulate requirements for hotlines.

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