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
– 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)
– 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?
– 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)
– 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?