By: Maurice Gilbert, Managing Partner of Conselium Executive Search
• Are ethics goals reasonable, clear, measurable and achievable?
• Is there an existing code of conduct?
• Do you regularly conduct employee surveys that include rating the ethics in the corporate culture?
• Can you cite an example of when a leader publicly supported an ethics/integrity issue?
• Are the CCO’s remarks or findings subject to pre-screening by members of the management team prior to submission to the Board of Directors?
• Can you cite how ethics and integrity are fully integrated into the organization’s operations?
• How has the organization articulated ethical standards and principles to third parties?
• Does the organization require transparency and accountability by having employees execute disclosure and conflict of interest statements?
• Has the company described its commitment to ethical behavior in the annual report?
• Is ethical conduct seen as a critical element in the promotion process?
• Are employees encouraged to speak up regarding ethical concerns and misconduct?
• Are callers and subjects of investigations provided confidentiality and due process?
• Are ethics and integrity questions incorporated into company cultural surveys?
• Is the CCO authorized to issue safe harbor letters for employees seeking advice?
• Does the company provide state-of–the-art ethics training?
• Is ethics training incorporated into the company’s general educational training programs?
• Is the ethics training program regularly evaluated for effectiveness and improvement?
• Does the company sponsor academic and/or professional events promoting ethical behavior?
Maurice Gilbert is Managing Partner of Conselium Executive Search, which specializes in placing Compliance Officers and Legal Counsel for clients in the U.S., Europe, Latin America and Asia Pacific. Maurice is also CEO of Corporate Compliance Insights, a worldwide publication devoted to governance, risk and compliance issues. Maurice can be reached at maurice@conselium.com or maurice@corporatecomplianceinsights.com.
