A series of Deloitte’s white papers onf ethics and compliance programmes, starts by saying that what separates a “good” ethics and compliance programme from a “great” one, are five key differentiators:

• tone at the top
• corporate culture
• compliance risk assessments
• chief compliance officer
• testing and monitoring.

There is a white paper on each ingredient.

Tone at the top

Deloitte believes that, “Reputation risks today are at least as great as strategic, operating and financial risks.” They recommend that the tone and direction is set by:

• the board whose key tasks include hiring the CEO and setting risks appetite which set the tone for the organization by how they tackle their tasks
• the CEO needs to “prioritize the development of a culture of integrity

Together the board and the CEO need to develop a sense of shared values which are the long-term strategies and successful implementations are based.

(For copy of white paper see here.)

Corporate Culture

More and more, culture is moving from a lofty, “squishy” concept to something that should be defined, measured, and improved, see:Source & Copyright©2015 - Deloitte

The Deloitte Ethics and Complance Framework is based on the belief that “an ethical culture is the core element of an organization’s ethics and compliance program.” (For the white paper on ‘Corporate culture’ see here.)

Compliance risk assessments

The white paper on compliance risk assessments argues that “corporates cannot mitigate risk if you don’t know it is there.” However, compliance risk is different from other risk assessments. Deloitte argues that “while compliance risk assessment should certainly be linked with the enterprise or internal audit risk processess, they generally required a more focused approach …. most organisations may be able to combine the activies that support risk assessments, perhaps following an initial compliance risk identification and assement process.” (For the white paper on ‘Compliance risk assessments’ see here.)

Chief compliance officer

The ‘Chief Compliance Officer’ (CCO) is the fourth ingredient for world-class ethics and compliance programmes. However, Deloitte have found that “It takes an extraordinary leader to uphold the integrity of an organization.” Furthermore, the CCO profession has begun to shift in various ways. Deloitte believes that, “World-class CCOs are more about starting conversations than shutting them down.” 

(For more see the white paper on ‘Chief Compliance Offers’ here.)

Testing and monitoring

The white paper on the fifth ingredient for world-class ethics and compliance programmes has yet to be published. CTMfile will bring you details in due course.

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CTMfile take: The Deloitte approach fits with AmeriHealth’s experience in introducing an ERM programme across the whole organisation which also avoided the ’squishy’ approach and ran a highly focussed programme - see, recommended.