Compliance & Ethics Professional - Society of Corporate ...

for regular ethics effectiveness assessmentsfrom an independent third party. Assessmentscome in all shapes and sizes. The closer theethics committee is to daily operations, themore comprehensive the independent assessmentshould be.In summary, ethics committees can meetthe requirements of the Federal SentencingGuidelines for high-level responsibility foreffective ethics oversight. They can serve amultitude of roles and responsibilities, butspecial care must be taken when those roleinclude the day-to-day operation of the ethicsmanagement processes. Such care will ensureemployee/member confidence in the organization’scommitment to independence andimpartiality in decision making.ConclusionNot every ethics assessment should be a systemsassessment. There is a time and placefor compliance and culture assessments, butwe should never forget that organizations arecomplex systems made up of interconnectedparts and are themselves part of larger, morecomplex systems, industries, and society.Often, to understand systems requires a systemicapproach.When the issue is change—fundamentaland ethically consistent change—the systemsassessment provides the decision-makers andchange leaders with the breadth and depthof information needed to make that changehappen and endure. The systems assessmentis the tool for today, when organizations areundergoing fundamental change in what theydo and how they do it, but are choosing tohold on to their core values, principles, andethics, and where the ultimate goal is the moreethical organization.As more and more vendors get into thisfield, it may be useful to the reader to recognizethat not every assessment measures thesame things or provides the same value tothose who read its results. An effective assessmentought to define:1. What data ought the Ethics office/functionbe required to provide to the board?2. What do those data mean? (e.g., How manycalls to the ethics line is a “good” number?)a. Where possible, current practices willbe identified and critiqued.b. Available options, including emerging“best practices” (where such exist) willbe discussed.c. An approach will be described thatguides board members in the determinationof how best to address theirspecific ethics oversight issues andneeds.d. Based on this presentation, it isexpected that board members can beincreasingly confident that they willmeet mandated requirements for ethicsoversight. Furthermore, they can beassured that they are reducing theirpersonal exposure while contributingto the realization of higher levels oforganizational ethics.This document and the recommendationsit presents are but a beginning to buildingboard member confidence, reducing a board’ssense of exposure, and providing individualboard members with the confidence that theyare meeting the requirements associated withthe oversight of organizational ethics. It representsa start of what is truly needed for boardsto effectively fulfill their fiduciary and legalobligations regarding organizational ethicsby providing a conceptual framework anda shared vocabulary necessary for ongoingdialog. ✵1. Sanford Krolick: Ethical Decision-Making Style, Survey andInterpretative Notes. 1987, Addison Wesley. ISBN 0-201-16412-4Frank J. Navran is the Founder and Principal Consultant of NavranAssociates. Frank has worked with clients in more than twenty countriesand has authored five books and more than two hundred articles andbook chapters. He may be contacted at frank@navran.com, or for moreinformation, www.navran.com.Compliance & Ethics Professional March/April 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 53