Minimum Requirements for ethics and compliance program
Essay
1. Standards and procedures, such as codes of ethics, that are reasonably capable of detecting and preventing misconduct
2. High-level personnel who are responsible for an ethics and compliance program
3. No substantial discretionary authority given to individuals with a propensity for misconduct
4. Standards and procedures communicated effectively via ethics-training programs
5. Establishment of systems to monitor, audit, and report misconduct
6. Consistent enforcement of standards, codes, and punishment
■ 7. Continuous improvement of the ethics and compliance program
Source Adapted from U.S, Sentencing Commission, Federal Sentencing Guidelies Manual, effective November 1, 2004 (St. Paul: West, 2008).