38. 38
Prioritization Matrix
High Return / Low Investment
Do first and do often
High Return / High Investment
Break down into smaller pieces
Low Return / Low Investment
Do when you have time
Low Return / High Investment
Say NO graciously!
69. 69
Compliance Programs
• Goal: self-policing and changing the corporate culture
to include a commitment to ethics and compliance
with civil and criminal laws.
• Double-edged sword: if a crime is committed in the
face of a compliance program, it may suggest that the
company is not truly committed to changing its
corporate culture.
70. 70
Compliance Programs, continued
• The compliance program must be designed to catch the
most likely misconduct given the corporation's primary
business.
• Whether the program is adequately designed for maximum
effectiveness in preventing and detecting wrongdoing by
employees;
• Whether corporate management is enforcing the program
or is it tacitly encouraging or pressuring employees to
engage in misconduct to achieve the business objectives;
and
• Investigators will interview rank-and-file employees to
determine the effectiveness of and commitment to the
ethics/compliance program.
• Is there an audit function so that the corporation can
determine its effectiveness?