In this  episode I visit with Vin DiCianni on how ethical culture is a part of an overall ethics and compliance program assessment and how to go about it. We began with an exploration around the areas assessed to help determine if a company has an ethical culture. DiCianni said you need a framework for such an assessment. DiCianni advocates  starting with the program itself. This means a review of what does the organization’s compliance program look like and does it meet the foundational tenants? He would ask such questions as whether it is educational; does it have a process for detection; and is there some type of remediation when something is found? From this baseline, you might consider what the company is doing for training to educate their staff, are they really touching on the elements of the parts of education that the staff need and is it meaningful to them in their positions? In other words, is the training both focused and effective?

DiCianni concluded with accountability. He said, “I think the other one that I can’t emphasize enough is accountability. You know if there are serious violations of an ethics policy of the company, be it conflicts of interest or code of conduct. If nothing is done about it, everyone in the organization knows about that. It diminishes all of the efforts that have gone into creating this program and trying to have an ethical culture. If you do not do anything to enforce it, when something serious happens, it literally becomes a futile exercise”.

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