Compass.jpgCompliance and Ethics efforts were largely unknown at organizations in the U.S. and elsewhere before the 1980s when, following a series of government procurement scandals ("Ill Wind"), several large defense contractors formed the Defense Industry Initiative on Business Ethics and Conduct. (See also the Ethics Resource Center's "business ethics timeline")

Sentencing Guidelines "Model"

On November 1, 1991 the United States Sentencing Commission created a substantial incentive to have and maintain an "effective" program in the form of a credit to organizations that despite having such a program nonetheless run afoul of a legal requirement that carries a criminal penalty. Since then C&E programs or elements of them have come to be a frequent part of settlements of all types of matters with the Department of Justice and other agencies by means of "Corporate Integrity" or "Deferred Resolution" agreements that essentially establish a probation period for the organization. (See Learning from Others' Missteps for examples.)

Here's a Commission description of what they were up to with their famous "Seven Elements" model for compliance efforts - and a graphic that may help you / others follow along: One of the Commissioners also described the purpose and operation of the Guidelines at a 2012 conference (video).


Although some mandatory compliance or ethics program requirements exist on both the state and federal level, in many industries C&E programs are still voluntary efforts. For some companies C&E is a public demonstration of the organization's efforts to be a good corporate "citizen"; for others it is a risk management device by which the organization's Board of Directors demonstrates that it is exercising appropriate oversight.

Translating Theory Into Practice

Here are:

  • links to descriptions of actual Compliance and Ethics efforts past and present and

  • a listing of and links to Associations devoted to compliance in various fields.

"How To" and "Why to" Materials:

Shared by Toolbox members:

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