An ethical culture is supported by top management, has incorporated ethics at all levels of the organization, and contains all of the components of an Ethics Program. A sample assessment questionnaire follows.

Support by top management
– Has management established an ethical “tone at the top” by setting a good example of ethical conduct, providing positive and open communication, and supporting ethical conduct?
– Are resources adequate for the organization’s ethics program?
– Is the ethics program reviewed at least annually by top management in light of changing business challenges?
– Is there a designated ethics officer or ethics contact?
– Does the ethics code start with a statement from the CEO/President about his commitment to an ethical culture?
– Does top management certify they have received ethics training?
– Does top management positively support the ethics hotline?
– Does ethics awareness material have the endorsement of top management?

Incorporation of ethics at all levels of the organization
– Is ethics a focus during regular top management meetings?
– Are supervisors trained as contact points for ethics related questions?
– Is ethics a focus during the hiring process?
– Is ethics a focus during new employee training?
– Is ethics a focus during employee evaluations?
– Is ethics a focus during supplier selection?
– Is ethics a focus during customer contract acceptance?
– Is ethics a focus during internal audits?
– Is an ethical culture ingrained in the organization’s brochures, materials, and website?

Components of an Ethics Program
Ethics Code
– Does the organization have a written ethics code?
– Does the ethics code cover key elements, such as conflicts of interest, financial irregularities, and compliance to laws?
– Do employees certify they have received and understand the ethics code?
– For publicly traded companies, is the ethics code available publicly / on the company’s website (ref. NASDAQ Regulatory Requirements rule 4350(n) / NYSE Listed Company Manual section 303A.10)

Ethics Training
– Do employees receive ethics training on a regular basis?
– Do employees certify they have received and understand ethics training materials?
– Does ethics training incorporate the company’s ethics code?
– Does ethics training incorporate the company’s ethics hotline?

Ethics Hotline
– Does the organization have an ethics hotline?
– Have all employees received information about ethics hotline usage?
– Is the ethics hotline confidentiality and non-retaliation policy clearly conveyed to employees?
– Does the organization provide ethics hotline information to employees and other shareholders via formats such as postings in break rooms and the company website?
– Are ethics hotline reports given priority and addressed consistently?
– Are ethics hotline reports reviewed for trends that suggest organization changes are required?
– For publicly traded companies, is the “receipt, retention, and treatment” of ethics hotline reports regarding “questionable accounting or auditing matters” aligned with the Audit Committee (ref. SOX section 301)

Ethics Awareness
– Is the importance of ethics communicated to all employees on a regular basis via formats such as organization newsletter articles and posters?
– Do the ethics articles cover topics that are interesting, engaging, and in pace with the times?