ECI Maturity Model - DRAFT
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ETHICS & COMPLIANCE PROGRAM<br />
MATURITY MODEL*<br />
PRINCIPLE<br />
1<br />
DEFINING<br />
S<br />
T<br />
R<br />
A<br />
T<br />
E<br />
G<br />
Y<br />
ETHICS AND<br />
COMPLIANCE<br />
IS CENTRAL<br />
TO BUSINESS<br />
STRATEGY<br />
UNDERDEVELOPED<br />
PROGRAM ELEMENTS:<br />
E&C PROGRAM DOES<br />
NOT EXIST OR IS NOT<br />
FOUNDATIONAL TO THE<br />
ORGANIZATION; WHERE<br />
E&C PROGRAM ACTIVITIES<br />
EXIST, THEY ARE<br />
DECENTRALIZED.<br />
• E&C is not formalized as a function<br />
within the organization. Where there<br />
are E&C program elements (e.g.,<br />
hotline, investigation process, etc.)<br />
in existence, accountability is<br />
decentralized.<br />
• E&C program is not well defined or<br />
understood and is very much an<br />
“add-on” (not embedded) feature of<br />
the organization.<br />
• There is no identified resource and<br />
advocate to help leaders across the<br />
organization understand their critical<br />
role in setting the standard for<br />
integrity. If a Code of Conduct<br />
exists, it is very much rules based.<br />
PROGRAM ELEMENTS:<br />
E&C IS ESTABLISHED, BUT<br />
IS NOT EMBRACED BY<br />
THE ORGANIZATION AND<br />
OPERATES TACTICALLY.<br />
• E&C is found as a function on all<br />
organizational charts, but is not<br />
considered an essential element<br />
within business operations.<br />
• E&C program is a recognized<br />
feature of the organization and is<br />
designed to support or complement<br />
certain day-to-day business operations,<br />
but it is not yet integrated with<br />
business objectives.<br />
• E&C exists as a resource to help<br />
leaders across the organization<br />
understand the organization’s<br />
standard for integrity.<br />
2
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