29. 29
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!
49. 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.
50. 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?