ECI Maturity Model - DRAFT

ETHICS & COMPLIANCE PROGRAM
MATURITY MODEL
A
C
C
O
U
N
T
A
B
I
L
I
T
Y
THE
ORGANIZATION
TAKES ACTION
AND HOLDS
ITSELF
ACCOUNTABLE
WHEN
WRONGDOING
OCCURS
PRINCIPLE
5
UNDERDEVELOPED
PROGRAM ELEMENTS:
NO FORMAL STRUCTURES
ESTABLISHED OR
COMMUNICATED REGARDING
CONSEQUENCES FOR
VIOLATIONS OR FOR
ESCALATION, TRACKING,
INVESTIGATION AND
ACCOUNTABILITY FOR
MISCONDUCT.
• Stated company values may mention
accountability, but standards,
scenarios, outcomes, consequences
are either not in existence, not
tracked, and/or not shared with
employees.
• Hotline for reporting concerns may
be in existence, but workforce is
generally not aware of it.
• Where hotline exists, management is
not generally aware of volume, type
and/or outcome of reported
concerns.
• There is no formal case management
and investigations are completed on
a case by case basis.
• No review of discipline for
consistency.
DEFINING
PROGRAM ELEMENTS:
ORGANIZATION HAS POLICIES
ADDRESSING STANDARDS AND
CONSEQUENCES; ESCALATION,
TRACKING AND INVESTIGATIVE
PROTOCOLS APPLY, BUT LACK
CONSISTENCY AND WITH LITTLE
ROOT CAUSE ASSESSMENT
OR TREND REPORTING TO
BUSINESS.
• Policy/Code of Conduct exists
for how employees are to be held
accountable for reporting and/or
misconduct; limited tone of accountability
from the top.
• Limited organizational understanding
of roles and responsibilities.
• Hypothetical misconduct scenarios
may be contained in employee
training on an ad hoc basis.
• Investigation standards apply to
all internal groups conducting
investigations, but may not be
applied consistently.
• Hotline for reporting concerns exists,
but it is not widely known or used
• Leadership generally aware of basic
hotline trends, but they are not used
to drive improvements.
• Procedure in place for internal and
external response in case of serious
misconduct harmful to company
reputation.
10
• No formal escalation and
response procedure.