"Check the box" isn't cutting it anymore with regulators and prosecutors:
Regulators now expect companies to instill ethical cultures to meet compliance objectives.
Amended Federal Sentencing Guidelines require companies to promote an organizational culture that encourages ethical conduct.
The next generation of ethics and compliance must focus on how the company's culture creates integrity risks. Does your organization know how to keep its good employees from being pressured to do bad things?
"Culture is a risk factor. People know what the rules are. It's the environment that dictates whether unethical practices are permitted to flourish." David Gebler