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Key Program Effectiveness Index Findings: Most Effective vs. Least Effective Programs

Several correlations of interest are noted by the Program Effectiveness Index (PEI), and taken together they suggest what’s working for Ethics & Compliance programs, and what isn’t. But the greatest differentiators—the things which the most impactful programs are doing and which the least impactful programs are not—are worthy of our attention. Collectively, they reinforce what most of us already know, such as the importance of tone at the top and embedding a program within the business organization. These findings clarify some of the ways in which those general principles come to life.
 
Compared to all the rest, the most effective 20 percent of programs are much more likely to:
  • Celebrate employee acts of ethical leadership, both in team meetings and other company communications vehicles
  • Have the following as key program goals: Innovate design and delivery of E&C education; Drive E&C functional efficiency; Adapt E&C programs to changing business needs; Focus on the validity and improvement of program metrics
  • Focus on people (use HR data) as a key element of risk assessment
  • Include social responsibility in their codes of conduct
  • Be consulted by their CEOs on senior management performance and promotions
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Topics: Program Effectiveness Index

The Program Effectiveness Index (PEI)

“Program effectiveness” is a term Ethics and Compliance (E&C) professionals frequently use. Naturally, they want to know that their companies’ investment and effort are paying off. In the United States, they are likely to be concerned about judicial and regulatory expectations of their programs. A primary source of those expectations is the Federal Sentencing Guidelines for Organizations, which specifically require a periodic evaluation of E&C program effectiveness. But what does it mean to have an effective program? Is it about more than program design and implementation? If so, what are its salient metrics? Our collective inability to settle on specific answers to these questions is a barrier to improvement.
 
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Topics: Program Effectiveness Index

Key Program Effectiveness Index Findings: What Really Matters When it Comes to an E&C Program

Spending, Staffing and Company Size Do Not Appear to Matter
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Topics: Program Effectiveness Index

When You Can’t Measure What You Value, You Tend to Value What You Can Measure

The first step to understanding what highly effective programs do is to identify which programs they are. While the fact or prevalence of misconduct seems as if it might be a useful starting point, two problems present themselves. First, misconduct has many causes, and an E&C program—no matter how effective—can no more take overall credit for an absence of misconduct than it can be blamed for an instance of it. Second, relatively few instances of misconduct are made known outside of the organizations in which they occur. 
 
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Topics: Program Effectiveness Index

Ethics & Compliance Program Effectiveness: Who Cares, and Why?

In 2012 corporations spent, on average, $54 per employee on ethics and compliance (E&C) programs ($76 per employee in highly regulated industries.)  That, by any reasonable standard, should be seen as a bargain. Still, the average spend keeps rising—by as much as 10% annually in recent years—and the number of programs and employees covered by them continues to grow.
Growing, too, are the roles and responsibilities associated with the typical ethics and compliance program, which now range from mundane necessities such as collecting annual code of conduct certifications or maintaining gift registries to essential missions, such as inspiring cultural transformations.  
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Topics: Program Effectiveness Index