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Compliance Codes
 


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The existence of an effective compliance program may be considered a mitigating factor which reduce a corporate penalty for federal offenses.   See 18 USC, sec 8A1.2 at note k.  The Federal Sentencing Guidelines contain the outline of what you want to have in place before your organization has a problem. 

Corporate counsel are more and more realizing the potential for reduced fines lies in having an effective compliance program in place before a problem develops.  Corporate officers are more and more realizing the program lessens the likelihood of claims against the corporation.  Corporate directors are more and more realizing the program develops a corporate character that can drive corporate performance upward.  So the Federal Sentencing Guidelines have been of benefit in producing a new management perspective on ethics.

http://www.triacnet.com/ is a good site for banking industry compliance issues.

www.ethics.org is the birthplace of a good text --- "Creating a Workable Company Code".  It give guidance on that process.   The organization is the "Ethics Research Center" (ERC).  The ERC has updated the 1990 publication "Creating a Workable Company Code of Conduct to become a good tool an organization develop and implement a code of ethical business conduct or ro revise existing standards and policies.   Included are sample survey, interview and focus group questions, a template and worksheet for writing code provisions, and a code development process checklist. Additionally, the new edition incorporates timely information on the US Federal Sentencing Guidelines, In Re Caremark, and the Sarbanes-Oxley Act of 2002. "Creating a Workable Company Code" pulls together information publicly available and information not previously published and melds the pieces together. $25 from the ERC.