ECI Maturity Model - DRAFT

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ABOUT ECI’S WORKING GROUPS The Ethics and Compliance Initiative (ECI), in an effort to encourage networking and collaboration among its members, offers multiple Working Group opportunities based on particular issues driven by member interest. The purpose of these 20-25 member groups is to help ECI members learn from one another via dialogue and through the sharing of resources, the benefits of which strengthen the larger ECI community. Working Groups are driven by a shared goal to produce a practical, action-oriented deliverable for the benefit of ECI’s members. CO-CHAIRS Karen Clapsaddle Lockheed Martin Corporation Steven Scarpino BP plc Robb Canning Ernst & Young, LLP Gerry Dawes Con Edison Company of New York Jack Giraudo Olin Corporation Rodney Grandon Affiliated Monitors, Inc. MEMBERS Suzanne Milton US Foods Maryn Sigurdson BP plc Cally Swanson US Bank Linda Trevino PSU Courtney Wallize Northrup Grumman Paul Zikmund Bunge Limited Tim McLaughlin L3 Technologies, Inc
BACKGROUND In 2016, ECI published the Blue Ribbon Panel report entitled “Principles and Practices of High-Quality Ethics & Compliance Programs” (the “HQP Report”). Since its publication, there has been interest by a number of members of ECI for additional guidance and/or a measurement framework to assist with assessing an ethics and compliance program. DISCUSSION AND DECISION BY ECI WORKING GROUP: The E&C Program Maturity Model Working Group met on a number of occasions to discuss developing a framework that could be used by organizations to measure their programs against those described in the HQP Report. The intent is to provide a framework that allows all organizations, big or small, profit or non-profit, to assess the effectiveness of their programs based on HQP elements. The Working Group decided to address each of the 5 HQP principles, according to maturity levels (see Methodology) 1) What to measure/review; 2) Questions to consider; 3) Potential Sources of Information and 4) Leading Practices Illustrative of HQPs. METHODOLOGY The Working Group developed a template with five levels or categories of maturity. The five levels are defined as: UNDERDEVELOPED – A new E&C program or an existing one that has not progressed far in embedding HQP elements. ADAPTING – An E&C program that has a few HQP elements, but still lacks many important attributes. DEFINING – An E&C program that contains a number of HQP elements reflecting some important attributes, but with room to further mature. MANAGING – An E&C program that can be considered “Good,” but not an HQP. OPTIMIZING – An E&C program which contains the majority, if not all, HQP elements. The Working Group developed this framework by first populating the Optimizing category from the objectives outlined in the HQP Report – representing the “High Quality Programs.” It then defined the other end of the spectrum by populating the “Underdeveloped” column, which describes the least mature level. The more difficult steps involved assessing the intermediate categories, i.e., defining the progression of program maturity among the three middle levels (Adapting, Defining and Managing). While the final category -Optimizing- provides indicia for a HQP, the intent of the fourth column is to define a “good” program. HIGH-QUALITY ETHICS & COMPLIANCE PROGRAMS | © 2018 Ethics & Compliance Initiative 1
Page 1: HIGH-QUALITY ETHICS & COMPLIANCE PR
Page 5 and 6: ADAPTING PROGRAM ELEMENTS: E&C BEGI
Page 7 and 8: ADAPTING PROGRAM ELEMENTS: A FORMAL
Page 9 and 10: ADAPTING PROGRAM ELEMENTS: LEADERS
Page 11 and 12: ADAPTING PROGRAM ELEMENTS: A FORMAL
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Page 15 and 16: PRINCIPLE 1 WHAT TO MEASURE/ REVIEW
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Page 23 and 24: JOIN A BENCHMARKING GROUP Your ethi

ECI Maturity Model - DRAFT

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