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Building World-class Ethics and Compliance Programs

Making a good program great


The U.S. Federal Sentencing Guidelines and, more recently, promulgations by the Organisation for Economic Co-operation and Development (OECD) Good Practice Guidance, have called for organizations to develop effective compliance risk mitigation programs and internal safeguards to protect against internal and external threats of corruption and fraud. Despite decades of experience in developing such practices, the results appear to remain uneven at best, which is especially concerning at a time when risks are increasing.

While ethics and compliance executives have come a long way in developing sophisticated measures to prevent, detect, and mitigate risk of malfeasance in their organizations, so, too, have those who wish to violate the rule of law and gain unfair advantage. “Good enough” today just is not good enough. Organizations should continuously strive for “great” in their ethics and compliance program.

What separates a “good” ethics and compliance program from a “great” one? While there are a number of factors that separate the “good” from the “great,” in our experience, here are five factors that are key differentiators in the highest performing compliance programs:

  • Tone at the top
  • Corporate culture
  • Risk assessments
  • Testing and monitoring
  • The chief ethics and compliance officer

Download the PDF to learn how in this fast-paced ever-changing world, now is the time to transform your “good” ethics and compliance program into a “great” ethics and compliance program.


Featured insights

Tone at the top: The first ingredient in a world-class ethics and compliance program
The tone at the top sets an organization’s guiding values and ethical climate. Properly fed and nurtured, it is the foundation upon which the culture of an enterprise is built. Ultimately, it is the glue that holds an organization together.  Learn how the board, the chief executive officer, and the chief compliance officer play critical roles in setting the tone at the top.


As used in this document, “Deloitte” means Deloitte & Touche LLP, a subsidiary of Deloitte LLP. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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