Involve all employees in compliance program.

• Author: Avery, Tyson M.
• Position: Ethics Corner

Tony Stark, hero of the summer blockbuster hit Iron Man, is CEO of the high profile defense company Stark Industries. Tony channels his brain power, bravado, and love for things that go boom and creates a deadly "cluster missile" (Jericho) for the U.S. military. Unbeknownst to Tony, his long-time friend and second in command at Stark Industries, Obadiah Stone, betrays Tony and sells the deadly Jericho to U.S. enemies and terrorists. Tony later is severely wounded by one of his company's own Jericho missiles.

Tony's misfortune could have been avoided if Stark Industries had put measures in place to prevent illegal sales of the Jericho. His company needed an ethics and compliance program, as do real-world corporations.

An ethics and compliance organization that operates in the "ivory tower" will never promote accessibility. Galvanizing employees at all levels of the organization, from the board room to the mail room, will pay off in huge dividends.

Tasking senior management is vital. Executives lead by example--for good or bad. Corporate leaders who actively understand this focus their words and actions to promote ethical conduct. Leaders being good citizens is not enough. They must proactively communicate the ethics and compliance message to the company as a whole.

The ethics and compliance program must be made a top priority to ensure its effectiveness. This often means creating a position for an ethics and compliance manager and embedding that position into the leadership staff. A compliance manager will have direct access to an organization's board of directors, president and key leaders. The compliance manager should brief senior leaders as a routine aspect of operational meetings. The compliance manager should also be involved in decision making processes of the organization.

Interaction with middle management and front-line supervisors is equally important. These leaders are actually in the best position to influence the behavior of individual employees. Not only can they create an ethical environment at the shop floor level, but they can also encourage employees to come forward with possible ethical or compliance concerns. The rank and file must be comfortable openly questioning ethics and proper conduct. They also must be well-trained to spot compliance issues, and know how to follow-up when they become aware of a potential violation.

Mid-level managers must prioritize an ethics and compliance program in order, proactively, to...