In a short essay, list the five-step process needed to embed positive ethics and values within the culture of the firm through its compliance program.
What will be an ideal response?
a. Step 1 is for the firm to do a risk/cultural assessment. It is during this step that
management asks its employees via surveys and interviews what their assessment of the firm’s culture is.
b. Step 2 is to review the current compliance program to determine if any revisions need to be made. It is during this stage that management determines whether any revisions need to be made pertaining to the reporting structure, the methods of communication for employees, and any other components of the current compliance program.
c. Step 3 is to review of current ethical policies and procedures of the firm to ensure both
the content and responsibilities coincide with the current ethical vision of the firm.
d. Step 4 is to review and revise, if necessary, the communication, training, and
implementation phases of the compliance program. It is during this step that any gaps that were identified in the cultural assessment in Step 1 can be resolved so there is no ambiguity about the ethical vision of the firm.
e. Step 5 is to develop an ongoing self-assessment of the compliance program. It would also be during this step that any revisions to the monitoring and reporting components of the compliance program would be adjusted if necessary.
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