From the January 2011 issue of InsideCounsel Magazine • Subscribe!

Stamp of Approval

Ford Motor Co.'s Director of Compliance Jim Carroll advocates third-party validation of a company's ethics and compliance program. Ford engaged the Ethisphere Institute, a think tank devoted to business ethics and corporate social responsibility, to review its program.

Ethisphere's anti-corruption validation process compares a company's program against a database of 2,000 companies' ethics policies and practices, according to Executive Director Alex Brigham. A company that falls within the top quadrant of the database is eligible for verification valid for two years.

"One component of the verification is analysis of the company culture," Brigham says. Key critical questions are: Do employees know all the applicable laws? Do they know where to raise a concern if they witness a violation? Will they actually raise the concern, or do they fear retribution?

Carroll says he found the review process valuable. "It forces you to step back, look at the program and make sure you are doing things in the most efficient and productive way," he says.

See the last page of this article for another sidebar.

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