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Assessment
 Ethics and compliance can be costly and time consuming. No company can afford to waste money and time on ineffective programs. For this reason, periodic assessments are critically important. Since 1993, we have conducted assessments for dozens of Fortune 500 companies in nearly every industry. Companies chose ELG because:
- In 2001, we pioneered a unique assessment methodology which combines traditional interviews and focus groups with state-of-the-art live surveys. Since then, we’ve accumulated an extensive proprietary benchmarking database.
- We began surveying companies in 1995. Our database is broad and deep includes in-depth data from every industry.
- The ELG team has over 100 years of experience in the ethics and compliance field. We’ve been in your position. We’ve run ethics and compliance programs. Experience helps us to know what to ask and what to look for. We’re your extra set of eyes.
Our assessments are rich in insights, based on practical experience, and backed-up by solid benchmarks and data.
While all of our assessments are tailored to the specific needs of our clients, as part of our assessments we are often asked to listen to the perspective of employees. Our focus-group methods enable us to gather information about employee perceptions, and to understand the cultural and attitudinal underpinnings of effective ethics and compliance. We dig deep, we hear more, we’re told more. Senior leaders and employees at every level open up to us.
Whatever type of assessment you need, we’ve done it, including:
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Surveys, Focus Groups and Benchmarking
ELG has been collecting and analyzing business, industry and country specific ethics and compliance data since 1994. Our International Business Ethics Survey database allows us to offer diagnostic and analytic insight on issues of program implementation and employee perceptions of key drivers of an effective ethics and compliance program.
Senior management typically places great weight in survey results, so we are scrupulous in every aspect of the process, whether we host a web based survey or conduct one using the mail. Unfortunately, surveys often raise as many questions as they answer. That’s why we often conduct focus groups to learn the underlying reasons for employee responses. Our focus groups include anonymous, live surveys using wireless keypads so that our experienced facilitators can instantly follow-up on the most fruitful areas of discussion.
Benchmarking is the third basic tool in our assessment toolkit. Information without context or insight is meaningless. We use our existing International Business Ethics Survey as a primary method for benchmarking, but often supplement this with qualitative and quantitative research of other companies in the client’s industry.
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Risk Assessments
Risk assessments are vitally important to ensure that ethics, compliance and corporate responsibility programs are cost-effective and aligned with the actual challenges facing your organization. The U.S. Sentencing Guidelines call on organizations to “periodically” assess their organization’s risk and to then “take appropriate steps to design, implement, or modify” their ethics and compliance program.
Our first step often is to work with management to identify existing risk management processes that are in-place but are not being fully utilized as part of an ethics and compliance review. Next we help compile existing internal information and we supplement it with our insights about other, emerging industry-specific risks. At this point, we may recommend leveraging an existing company process, or customize one of our risk assessment tools to facilitate efficient implementation within the company.
The end result of an effective risk assessment is not simply a list of risks, even though it may have frequencies, magnitudes and priorities as part of it. In the end a good risk assessment forms the basis for a forward looking compliance plan to remediate the unique risks (ethical, cultural and compliance) for your company and in your industry.
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Ethics and Compliance Assessments
What do you do when your CEO, General Counsel or the Chair of your Audit Committee asks you if you have an effective compliance program? You may look to Internal Audit for an analysis, or do a self assessment. Sometimes, however, an independent, expert analysis is the right step–not just to reassure management, but to help target your efforts most efficiently and economically. At ELG we have the experience to ask the right questions and to help determine if your ethics and compliance program is truly effective. We do extensive review of documents and processes, along with interviews, surveys and focus groups, to answer questions like the following:
- Do employees know the Company’s values and ethical standards that they are expected to live up to?
- Are training and communication adequate to address the unique roles and responsibilities of employees at various levels of the Company?
- Do employees believe that they can report misconduct without fear of retaliation?
- Is the Company getting the right number of calls? The right type?
Ethics and compliance program assessments may focus on one program element, like the Code of Conduct, training, or helpline process. Or they may focus on a specific risk area, like Bribery or Fair Competition/Antitrust. Most frequently, clients ask us to conduct a comprehensive review of the entire program, including an assessment of culture (see below).
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Culture Assessments
It is a well-known maxim that culture trumps compliance. The 2004 revisions to the U.S. Sentencing Guidelines recognize this and require organizations to ensure that there is a corporate culture in place that “encourages ethical conduct and a commitment to compliance”.
At ELG we’re proud of the leading role that we’ve played over the years in recognizing the importance of culture and developing tools to measure it. Ed Petry was primary author of the Culture Section of the U.S. Sentencing Commission’s Report of 2004, and we’ve been chosen to design and lead national conferences on the topic. We authored the Culture Section of the U.S. Sentencing Commission’s Report of 2004 and we’ve been chosen to design and lead national conference on the topic.
Our expertise is based on our long experience running ethics and compliance programs and the dozens of in-depth culture assessments that we have done for Fortune 500 companies over the years.
We dig deep. We study your corporate history and folklore, we listen to the grapevine, we get employees to open up and tell us what they really think, we compare rhetoric with actions, and we listen to what employees feel they can’t share with you.
Our in-depth Reports identify the multiple subcultures that make up your company, provide charts and tables dissecting survey and focus group data against our benchmarks and include analysis of how you cultures can be relied on to support ethics and compliance, as well as where there are obstacles undermining your best efforts. Every Report concludes with practical recommendations for improvements.
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Integrity Diagnostics, Helpline Assessment
One of the best ways to understand exactly what's happening "on the ground" at your company is to look at the issues being reported by your employees. By understanding the "whys" and "hows" of employee reports, you gain unique and distinct insight into the culture at your company.
Integrity Diagnostics does that, and compares your reporting trends to benchmarks in your industry and across industries, with expert recommendations on how to make improvements and address concerns. Click here to learn more.
Additionally, ELG's expert consultants can do "deep dive" assessments of your reporting system, to maximize its effectiveness.
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Due Diligence in Mergers and Acquisitions
Too often mergers and acquisitions fail because of cultural differences that should have been recognized and addressed at the outset. We have also seen examples where two companies have vastly different approaches to ethics and compliance which result in years of struggle, acrimony and unpredicted litigation.
ELG can conduct due diligence investigations of the target company’s ethics, compliance and corporate responsibility efforts and highlight potential areas of conflict and concerns. Included in the analysis is an assessment of the company’s This internal examination is supplemented by a “background check” on the target company’s ethics and compliance history and reputation.
Ethical due diligence is valuable not just for avoiding unknown risks, but for identifying areas to target during post merger integration efforts.
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