No compliance officer worth her salt would argue with this statement: “We strive to maintain an ethics-based organization.” But compliance teams, with all of the internal and external scrutiny, with all the regulations and increased enforcement activities, with the ever-present mantra of “always do the right thing,” still to this day have difficulty instilling a true ethics-based culture into their compliance programs. They struggle to define it, to measure it and prove its ongoing value to the organization.
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