The New DOJ Guidance on Code of Conduct & Part One of a Special Interview with Alison Taylor

How does the new Department of Justice’s new guidance, the Evaluation of Corporate Compliance Programs, from February 2017 approach the requirements for written standards, including code of conduct? Eric walks through three key takeaways from the Evaluation of Corporate Compliance Programs on how organizations should document and conduct their code of conduct development and review process. We also have Part One of a two part Special Interview with Alison Taylor of BSR on her new white paper, The Five Levels of Organizational Culture. While neither the new guidance, nor the Sentencing Guidelines that proceeded it by 25 years, speak specifically about code of conduct, it does establish standards for development, maintenance and assessment of “policies and procedures” — much as the Sentencing Guidelines speak to “written standards”. Reading this new guidance should be a wake-up call for organizations that do not currently have an established process for review and revision of their code and other written standards. There is a clear expectation that organizations will have a plan, involve a cross-functional team and periodically assess their progress and success.  In this podcas,t Eric will talk about those expectations and what organizations should consider. Alison Taylor’s recent white paper, The Five Levels of Organizational Culture, provides a lot of food for thought on how to implement ethical culture in an organization. She examines five different levels of ethical culture that need to be considered and we walk through her findings. In Part One of a two part interview, we talk about the intersection of individual ethics and the broader corporate culture.  Alison heads the sustainability management practice at BSR.