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How to Implement an Ethics Program

Author: John Sarno, Employers Association of New Jersey

Many firms have implemented an ethics program as a sound business practice. Some do so because they are competing for federal contracts of a certain size and must satisfy the Federal Acquisition Regulations mandate. Others implement a program to satisfy standards under state and Federal Sentencing Guidelines or under the Public Company Accounting Reform and Investor Protection Act (the Sarbanes-Oxley Act of 2002). Still others view such a program as in integral part of a risk management strategy or corporate governance structure. In each case, an ethics program begins with a code of ethics, a communications strategy and, in many cases, organization-wide training. Depending on the size and type of the firm, an effective ethics program also includes identifying an ethics officer to investigate and resolve issues and establishing a freely accessible and anonymous hotline for employees.