Practical Applications of the Code of Ethics for Compliance & Ethics Professionals

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Society of Corporate Compliance and Ethics 6500 Barrie Road, Suite 250, Minneapolis, MN 55435, United States www.corporatecompliance.org | +1 952 933 4977 or 888 277 4977

Practical Applications of the Code of

Ethics for Compliance & Ethics

Professionals

Urton Anderson, CCEP

Marjorie Doyle, JD, CCEP -F

Chair, Department of Accounting Principal

University of Texas at Austin Marjorie Doyle & Associates LL C

urton@mail.utexas.edu

marjoriedoyle@comcast.net

www.corporatecompliance.org | +1 952 933 4977 or 888 277 4977

Agenda

• Why a Code of Ethics?

• Structure of the Code

• How the Code of Ethics for Professionals can help in making tough

decisions

• How others are using the Code

• How to educate your team and your management on the Code

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Why a Code of Ethics?

• Promote an ethical culture for the compliance profession

• Clarifies the compliance professionals ethical responsibilities

• Sets expectations for those who rely on the work of compliance

professionals

• Provides guidance in resolving ethical dilemmas

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Where did the code come from?

• HCCA Professional Code of Ethics (1999)

• Code of Ethics Development Committee(2007)

–

JOE MURPHY

–

REBECCA WALKER

–

URTON ANDERSON

–

MICHAEL HOROWITZ

–

SHELLY MILANO

–

MARJORIE DOYLE

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The Framework

• Principles: broad standards

1. Obligation to Public

2. Obligation to Employing Organization

3. Obligation to the Profession

• Rules of Conduct: minimum level of professional

conduct for CEPs

–

17 rules

• Commentary: clarifies/elaborates on the Rules

The Framework

• Three Principles: broad standards - obligations to the

public, the employing organization & the profession

• Rules of Conduct: minimum level of professional

conduct for CEPs

• Commentary: clarifies/elaborates on the Rules

• Enforcement: primarily - CEP’s own

understanding/voluntary actions

secondarily - peers & general public.

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Principle I

Obligations to the Public

Compliance and ethics professionals

(CEPs) should abide by and promote

compliance with the spirit and the letter of

the law governing their employing

organization’s conduct and exemplify the

highest ethical standards in their

professional conduct in order to contribute

to the public good.

R 1.2

• CEPs shall take such steps as are necessary to

prevent misconduct by their employing

organizations.

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“Misconduct” includes

both illegal acts and

unethical conduct

Principle II

Obligations to the Employing Organization

Compliance and ethics professionals

(CEPs) should serve their employing

organizations with the highest sense of

integrity, exercise unprejudiced and

unbiased judgment on their behalf, and

promote effective compliance and ethics

programs.

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Principle III

Obligations to the Profession

Compliance and ethics professionals (CEPs)

should strive, through their actions, to uphold the

integrity and dignity of the profession, to

advance the effectiveness of compliance and

ethics programs and to promote professionalism

in compliance and ethics.

How the Code of Ethics for Professionals can help in making

tough decisions

Case 1

The Case of the Fishy Fishing Trip

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How the Code of Ethics for Professionals can help in making

tough decisions

Case 2

The Case of the Unknown Risk

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How the Code of Ethics for Professionals can help in making

tough decisions

Case 3

The Case of the Perilous Inquiry

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How the Code of Ethics for Professionals can help in making

tough decisions

Case 4

The Case of the Hackneyed CEP

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How the Code of Ethics for Professionals can help in making

tough decisions

Case 5

The Case of the Compromising Spouse

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How the Code of Ethics for Professionals can help in making

tough decisions

Case 6

The Case of the Muffled Orator

17

How the Code of Ethics for Professionals can help in making

tough decisions

Case 7

The Case of the Twitters

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How others are using the Code

How do you use the Code?

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How to educate your team and your management on the Code

• Incorporate in compliance function charter

• Refer in terms of employment or engagement

• Include the Code in organizational compliance training

• Give copies of the Code to Board members and managers

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Questions?

Urton Anderson

McCombs School of Business

The University of Texas at Austin

(512)471-5339

urton@mail.utexas.edu

Marjorie Doyle

Marjorie Doyle & Associates LL C

(484)508-8153

marjoriedoyle@comcast.net

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