Corporate Ethics Program Process

Transcription

1 Corporate Ethics Program Process Comprehensive Appraisal Questionnaire Program Assessment Employment Survey Cultural Assessment Analysis Preparation of Code of Ethics Development / Assessment of Internal Controls Corporate Compliance Measures Audit Practice Reporting Standards Hotline Onside Annual Ethics Training Historical Response To Misconduct

2 Is Your Ethics Program In Order? A robust and effective ethics program is essential to your business. Companies with gold star ethics programs know that: It is cheaper to stay out of trouble than to get out of trouble. A company championing an aggressive ethics program have happier employees. Contracting officers are more willing to work with contractors they trust. Ask yourself: 1. Do you contract with the government? 2. Are you compliant with the regulations of each state, country, or foreign territory in which you operate? 3. Does a significant portion of your business depend on state or federal contracts? 4. Do you have federal contracts in excess of $1 million? 5. Do you have long term and largely unchecked relationships with sub consultants? 6. Do you have a Code of Business Ethics? 7. Are your policies and code of conduct reviewed periodically? 8. Do you employ an ethics or compliance officer? 9. Do you currently provide annual ethics training? 10. Do you have an employee hotline? 11. Do you post any information relating to the reporting and detection of fraud? 12. Do you conduct audits of cost reports, time sheets, discretionary spending? 13. Are you maintaining the confidentiality of bid or proposal information? 14. Do you contract or employ lobbyists or consultants for business development purposes? 15. Do you employ former governmental employees or any employees or officers who hold public office? We are available to discuss your responses and tailor an ethics program to your needs.

3 Corporate Ethics Program Process Today s Reality Companies are paying millions of dollars to settle avoidable criminal and civil claims stemming from ethical lapses. Ethical lapses necessitate internal investigations that often cost time and money, beyond the expense of the underlying penalties. Beyond penalties, contract termination and debarment can result when a company fails to act ethically. Procurement fraud remains a top priority for the US Department of Justice. Refining internal controls and developing awareness through ethics programs are essential to mitigate risk of dishonesty and exploitation We assess our client's specific needs and recommend an ethics program tailored to its business. A robust ethics program should mitigate costs associated with unexpected investigations and the defense of criminal prosecutions and civil enforcement actions. Key reasons for implementing an ethics program: A properly executed program will inform management of potential problems before they become costly mistakes. The existence of an effective ethics program can provide documented standards and deter both government investigations and private lawsuits against a company. Enables a business to operate at peak performance while complying with all applicable laws and regulations. Creates and fosters a culture of transparency for the benefit of employers and employees alike. It is less costly to stay out of trouble than to get out of trouble. Reassures employees of ethical behavior and avoids costly turnover. Customers are more willing to work with companies they trust. Our services include: Assessing a client's need for an ethics program or the effectiveness of an existing program. Analyzing a client's current ethical culture through surveys and face to face interviews. Developing or refining a client's written code of ethical conduct. Designing and implementing comprehensive internal controls. On location employee training and periodic retraining, as necessary. Producing a series of presentations on specific topics customized to meet a client's needs. Implementing a confidential ethics hotline. Developing protocols for responding to ethical misconduct.

4 COMPANY DEMOGRAPHICS ETHICS PROGRAM DEVELOPMENT CLIENT INTAKE FORM 1. How many offices do you currently operate? 2. Where are they located? 3. How many employees work in each office? 4. Identify all supervisors and provide their job descriptions. 5. Identify all former governmental employees, date of hire, and nature of former governmental employment. 6. Identify any employees who hold positions as public officials or public employees. This would include any elected office and might be positions such as borough council members, school board members, members of municipal authorities, and/or township supervisors. 7. Do you conduct regular performance reviews of your employees? 8. Provide a corporate organizational chart. 9. Provide a chain of command structure for each office and the organization as a whole. Page 1 of 4

5 COMPANY OPERATIONS 10. In which states, foreign countries, or foreign territories do you operate? 11. Do you contract with the government? 12. What percentage of your business involves federal contacting? 13. What percentage of your business involves state contracting? 14. What is the largest federal contact awarded to date? 15. What is the largest state contract awarded to date? 16. Identify long term relationships with sub-consultants. 17. Provide any personnel files relating to employee misconduct. EXISTING ETHICS PROGRAM EVALUATION 18. Provide all codes of conduct, employee handbooks, and personnel policies. 19. Do you have a Code of Business Ethics? 20. Are your policies and code of conduct reviewed periodically? 21. What training materials and employment materials are provided to employees during the onboarding process? Page 2 of 4

6 22. Do you employ an ethics or compliance officer? 23. Do you currently provide annual ethics training? 24. Do you have an employee hotline? 25. Do you post any information relating to the reporting and detection of fraud? 26. Do you conduct audits of cost reports, time sheets, discretionary spending? If so, please provide audits for the past fiscal year. 27. Provide any contractor integrity provisions entered into with any public entity. 28. Provide a list of all public entities you are currently under contract with. 29. Have any employees been suspended or debarred? If so, provide all documents relating to the incident. 30. Have you had any government contracts terminated or rescinded? If so, why? FRAUD PREVENTION AND DETECTION 31. Identify all employs involved in the procurement process with any governmental entity. 32. Where is government procurement information maintained? Who has access? Page 3 of 4

7 33. Are bids or proposals marked appropriately to provide for confidentiality and prevent disclosure? 34. Do you contract with or employ lobbyists or consultants for business development purposes? Page 4 of 4